Mozambique

Corporate - Withholding taxes

Last reviewed - 30 July 2020

Any non-resident entity carrying out economic activities in Mozambique, without being registered as a taxpayer, is liable to a final and definitive 20% WHT that is applied on all income earned. An exception exists for (i) telecommunications and international transport, as well as the respective installation and assembly of equipment made by those same entities, (ii) construction and rehabilitation of production, transport, and distribution of electricity infrastructures in the rural zones under the public projects of rural electrification; and (iii) maritime vessels freight for fishing and coasting activities, all of which are subject to a 10% WHT rate.

Both Mozambican resident and non-resident recipients are liable to tax on dividends at a tax rate of 20%.

Tax treaties

In accordance with Mozambique's DTTs, the following tax rates are applicable to dividends, interest, and royalties:

Recipient WHT (%)
Dividends Interest Royalties Capital gains on shares
Non-treaty 20 20 20 20
Treaty:        
Botswana 0/12 (4, 5) 10 10 0
India 7.5 10 10 0
Italy 15 10 10 0
Macau 10 10 10 0
Mauritius 8/10/15 (1, 2, 3) 8 5 0
Portugal 10 10 10 (6)
South Africa 8/15 (1, 3) 8 5 0
United Arab Emirates 0 0 5 0
Vietnam 10 10 10 0

Notes

  1. The 8% rate applies if the recipient of the dividends is a company that has more than 25% of the share capital in the company that distributes the dividends.
  2. The 10% rate applies if the recipient of the dividends is a company that has less than 25% of the share capital in the company that distributes the dividends.
  3. The 15% rate applies in all other cases.
  4. The 0% rate applies if the recipient of the dividends is a company that has more than 25% of the share capital in the company that distributes the dividends.
  5. The 12% rate applies in all other cases.
  6. Gains are only taxed in the other state if assets of the entity sold are composed of more than 50% immovable assets.