Angola

Taxable period

The tax year follows the calendar year.

Tax returns

The annual CIT return for companies under the general and simplified regime must be submitted by the last business day of May and April, respectively, following the year to which the income relates.

Payment of tax

Taxpayers under the general regime that record sales and services excluded from WHT are required to make advance CIT payments by the end of August.

This tax is calculated by applying the rate of 2% to the total amount of sales and services excluded from the application of CIT WHT recorded by the taxpayers in the first half of the tax year. Advance payments may be offset against final CIT assessed.

The taxpayers may assess the 2% provisional payments of CIT due on sales based on the actual amounts received (rather than the turnover), but, in such cases, they are required to deliver the bank statements to the tax authorities.

Taxpayers with tax losses in the previous year may be exempt from the 2% provisional payments of CIT on sales. 

The taxpayers that replace their suppliers in the issuance of invoices (considering the self-invoicing regime defined in law) should, at the moment of payment to the supplier for the provision of goods, withhold 2%.

The final tax must be settled by the last business day of the month of April (simplified regime) and May (general regime) of the following year.

Tax audit process

The tax authorities may carry out tax audits to the monthly and annual tax returns.

Taxpayers may challenge any decision and file an appeal to the Chief of the respective Tax Office within 30 days upon receiving the tax notification.

Based on an unsatisfactory decision of the Chief of the Tax Office, the taxpayer may also file a hierarchical appeal addressed to the President of the Tax Authorities Executive Board (AGT) within 30 days upon receiving the tax notification.

The taxpayer still has the right to appeal against the final decision of the AGT in court within 60 days upon receiving the final decision from the tax authorities.

Statute of limitations

The statute of limitations in Angola is generally five years but may be extended to ten years in case of a tax crime. It is also ten years when relating to property tax on the transfer of real estate.

Topics of focus for tax authorities

The tax authorities' main areas of focus are related to:

• WHTs due (regarding several taxes: CIT, property tax, IIT, and PIT).
• 1% stamp tax on receipts, both from resident and non-resident entities.
• Deductibility of costs for CIT purposes (foreign exchange differences, cost of goods sold, provisions, donations, exemptions relating to tax benefits, unduly documented expenses).
• Consumption tax on production and on services provided by foreign entities (revoked as of October 2019).
• VAT.
• IIT on deemed interest.
• Transfer pricing.

Legal regime on invoices and equivalent documents

Invoices or similar documents must comply with the legal regime of invoices and similar documents (governed by the Presidential Decree 292/18).

Invoices and similar documents must comply with the following requirements (amongst others):

• Include the name, firm, tax address, and tax number of the supplier.
• Be duly dated, sequentially numbered.
• Include details on the nature, quantity, and price of the goods and services, as well as the taxes due.
• Be written in Portuguese and expressly mention that they were computer processed.

The legal regime of invoices and similar documents also established the following rules:

• The existence of a monthly generic invoice for banking institutions.
• Issuance of invoices in triplicate, being the triplicate used to accompany the transport of goods.
• Obligation to issue invoices in a programme certified by the tax authorities, applicable to taxpayers with a turnover above AOA 10 million - as provided for in Circular No. 002/DSIVA/AGT/2022.

Suppliers that do not comply with this regime are subject to fines and penalties. In addition, the acquiring entities cannot deduct the cost for CIT purposes and will be subject to an autonomous taxation on an amount that varies depending on the extent of the failure.

Additionally, from a VAT perspective, the VAT assessed in invoices that does not comply with that foreseen in the Law is not deductible.

Legal regime for self-billing

Presidential Decree No. 144/23, of 29 June 2023, approved the new legal regime for self-billing. 

The main changes reflect the legislator's will to encourage the use of the self-invoicing mechanism, making the regime simpler and more comprehensive. 

This regime updates the following rules: 

• The regime now covers the acquisition of handicrafts and manufactured products, as well as the acquisition of movable property subject to registration, acquired by natural persons for their own use for more than six months. 
• Sellers' registration obligations attributable to the purchaser are no longer required. 
• The value from which entities engaged in wholesale trade activities must report acquisitions made to the same seller to the AGT changes from AOA 1 million to AOA 25 million.

Legal framework on electronic processing and recording of tax procedures

Presidential Decree no. 95/23, of 6 April 2023, approved the new Legal Framework on the Electronic Communication and Processing of Tax Procedures and Tax Execution Procedure. 

This regime sets out new rules applicable to notifications and other communications of tax procedures by electronic means.

This regime mainly updates the following rules:

• In addition to the taxpayers previously covered by this electronic communication regime (i.e. Large Taxpayers, taxpayers with a turnover or imports exceeding AOA 50 million, and tax representatives of non-tax residents), individuals or corporate entities owning real estate, cars, aircraft, boats, and other goods subject to property tax or to tax on motor vehicles are also covered by the regime.
• Taxpayers are considered notified on the date they login to the tax authorities’ portal or five days after the tax act is made available on the portal (previously this deadline was one day).