The General State Budget for 2024 was enacted by means of Law No. 15/23, of 29 December 2023 (“State Budget Law”), which entered into force on 1 January 2024. The State Budget Law maintains some of the tax provisions introduced by former State Budget Laws for 2022 and 2023 (notably on Special Gaming Tax, Inheritance and Gift Tax on Movable Property and Motor Vehicle Tax), but also includes relevant innovations, notably a new Special Contribution on Foreign Exchange Operations and changes regarding Personal Income Tax and Industrial Tax.
The main tax and customs measures applicable in 2024 are as follows:
1. Special Contribution on Foreign Exchange Operations (“Special Contribution”)
- The new Special Contribution is levied on transfers of funds abroad made under contracts for the provision of services, technical assistance, consultancy and management, as well as foreign exchange capital operations and unilateral transfers.
- The following transfers of funds are excluded from the scope of the Special Contribution:
- those intended for health and education expenses, provided that they are paid directly into the bank accounts of the health or education institutions.
- dividends.
- the repayment of loan capital, including the payment of interest.
- Natural or legal persons residing or having their registered office in Angola who request a financial institution for transfers covered by this framework are liable to the Special Contribution.
- The Special Contribution shall be assessed on the amount of the transfer in national currency (AOA) at a rate of 10% for transfers made by companies and other legal entities or at a rate of 2.5% for transfers made by individuals.
- The taxable event is the transfer of funds. Although the taxpayer is the individual or entity making the transfer, commercial banks are the ones obliged to collect and remit the Special Contribution to the Public Treasury.
- The State, Petroleum Investor Companies, and Diamond Companies are exempt from the Special Contribution.
- The Special Contribution applies to transfers as of 1 January 2024.
2. Personal Income Tax (“PIT”)
- Income earned up to the limit of Kz 100,000.00 (one hundred thousand Kwanzas) is exempt from PIT, and the applicable PIT rates are updated accordingly.
- The rate of 6.5% applicable to the taxable income corresponding to the volume of sales of goods and services not subject to withholding tax of Group C taxpayers whose turnover was equal to or less than Kz 10,000,000.00 (ten million Kwanzas) in the 2023 financial year, is maintained.
- It is determined that the rules for calculating the taxable income of taxpayers under the general Industrial Tax regime should apply to Group C taxpayers who keep accounting records, with the necessary adaptations.
3. Industrial Tax
- Asset variations and hidden capital gains or losses resulting from fair value accounting will be tax neutral (will not be considered in the 2023 tax year as income or costs for the purposes of computing taxable income).
- Depreciation costs over amounts resulting from the fair value accounting exercise will not be accepted for tax purposes.
- Subject to prior authorization from the General Tax Administration, the costs incurred by taxpayers in the agricultural and livestock sector, with investments in infrastructure necessary for the production and disposal of products, benefiting the communities where they are located, notably in the cases of water, electricity or access roads, will be depreciated over the 5 (five) financial years following the investment.
4. Special Gaming Tax
- The Special Gaming Tax rates set out in the 2023 State Budget are maintained, with different rates applying depending on the type of games, and the exemption for prizes of Kz 200,000 or less is maintained for all types of games.
- Vending machines are subject to the rules governing table games.
5. Inheritance and Gift Tax on Movable Property
- The tax rates set out in the State Budget for 2023 of 0.5% (up to Kz 5,000,000.00) and 1% (above Kz 5,000,000.00) on transfers between spouses or to descendants and ascendants, and 1% (up to Kz 5,000,000.00) and 2% (above Kz 5,000,000.00) on transfers between any other persons, are maintained.
6. Motor Vehicle Tax
- Tax rates set in the State Budget for 2023 remain unchanged.
7. Customs Provisions
- The extension of the rules of the General Tax Code on payment in installments to customs debt is maintained in the following cases: i) when the customs clearance procedure for goods imported with deferred payment of duties and other customs charges has taken place; and ii) in the case of additional tax resulting from a post-import audit process.
8. Tax enforcement proceedings
- Taxpayers who have failed to comply with any tax obligation do not qualify as taxpayers with a regularized tax situation.
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