Angola

Corporate - Group taxation

Last reviewed - 25 June 2024

Major taxpayers that are members of an economic group may opt to be taxed under the tax regime of group taxation.

The option for the group taxation regime is available when:

The company is included in the major taxpayers list.
The parent company holds, directly or indirectly, at least 90% of the share capital of other companies (controlled entities), and more than 50% of the voting rights.

Some limitations apply, and the option to apply group taxation depends on the approval of the tax authorities.

Transfer pricing

In October 2013, Angola enacted specific transfer pricing legislation through the Presidential Decree 147/13. Although published on 1 October 2013, the provisions of the decree became applicable to tax years starting on or after 1 January 2014. This legislation imposes rather demanding obligations on taxpayers.

According to Angola’s transfer pricing requirements, all taxpayers (not just large taxpayers, as per Law 26/20 of 20 July 2020), whose annual turnover exceeds AOA 7 billion at the end of the fiscal year must prepare and submit a transfer pricing documentation file within six months of the fiscal year's end.

Furthermore, in 2020, the National Bank of Angola issued a Circular Letter 002/DCC/2020 that provides guidelines for banking financial institutions regarding validating payments under service contracts with non-resident entities. It mandates that such contracts demonstrate arm's-length pricing through either transfer pricing documentation (for large taxpayers) or benchmarking studies (for other taxpayers).

Finally, while Angola is not an Organisation for Economic Co-operation and Development (OECD) member state, its transfer pricing rules align with the recommendations of the UN Transfer Pricing Manual.

Thin capitalisation

Interest arising from shareholder loans should be deductible for tax purposes up to the limit that would result from the annual average interest rate established by the Angolan Central Bank.