Mozambique

Resident entities are subject to corporate income tax (CIT) based on their worldwide income.

Non-resident entities with a permanent establishment (PE) in Mozambique are subject to CIT on the income attributable to the PE in the Mozambican territory (i.e. income directly allocated to the PE, as well as any other income sourced in Mozambique derived from activities that are of the same or similar kind as those performed through the PE).

Non-resident entities without a PE or whose income is not attributable to a PE in Mozambique are only subject to CIT on the income sourced from Mozambique.

Resident entities and non-resident entities with a PE in Mozambique are subject to CIT that is levied on taxable profits, defined as accounting profits adjusted to comply with tax law rules, at a tax rate of 32%.

Non-resident entities without a PE or whose income is not attributable to a PE in Mozambique are generally taxed through a final and definitive withholding tax (WHT) of 20% or 10% (applicable to certain income only) that is applied on the gross income earned. There are also instances (e.g. capital gains) where non-resident entities are required to register themselves as a non-resident taxpayer, appoint a tax representative in Mozambique, file the necessary tax return, and subject the income/gain to CIT at a rate of 32%.

Autonomous taxation

Confidential and illicit expenses, as well as any expenses without proper supporting documentation, are subject to autonomous taxation at a rate of 35%. It is self-assessed in addition to CIT (even if no CIT is due). The effective tax rate on these expenses may reach 67%, given that they are not deductible for purposes of determining the taxable profit.