Mozambique

Changes to the Personal Income Tax (PIT) Code

Law No. 11/2025, of 29 December 2025, published in the Official Gazette No. 248, introduced a set of amendments to the PIT Code.

The main highlights of these amendments include the following:

• Residence criteria: The tax residence criteria have been amended. The previous 180-day physical presence test has been repealed. A person is now regarded as a tax resident if they have their main residence in Mozambique, their principal professional activity is carried on there, or the centre of economic interests is there, regardless of nationality or the duration of physical presence.
• Digital economy taxation: A 10% withholding tax (WHT; as a final tax) applies when such income is paid by Mozambican tax residents. Further regulations on this regime are expected.
• Electronic currency commissions: Commissions on electronic currency transactions are subject to a flat 10% WHT rate at source. Further regulations on this regime are expected.
• Capital gains: Capital gains are subject to autonomous taxation at progressive rates ranging from 10% to 32%.
• Rental income: A deduction from the gross rental income of up to 30% is available for duly documented conservation and maintenance expenses, as well as interest paid to Mozambican credit institutions on loans credit for the construction of owner-occupied housing. Rental income is now subject to a flat 20% WHT rate. The deduction of 30% to the WHT rate is eliminated.
• WHT on employment income: The provision deeming income tax withheld on employment income to be a final tax has been repealed. The exemption from filing an annual tax return (Modelo 10) for individuals who received only employment income already subject to monthly tax withholdings was also repealed.
• Elimination of special regimes: The simplified and exempt regimes have been abolished. Taxpayers registered under those regimes must migrate to the statutory accounting regime.

This Law entered into force on 1 January 2026. The government must issue the respective implementing regulations within 180 days.