Angolan industrial tax rate for special taxation regime to drop to 6.5%

Angola has amended the Industrial Tax Code, with changes entering into force on January 1, 2023, according to the official legal database Legis-PALOP+TL.

As of January 1, 2023, the Angolan industrial tax rate applicable to the Special Taxation Regime for Occasional Services (STROS) will drop from 15% to 6.5%.

The STROS regime covers legal entities that do not have their head office, effective management, or permanent establishment in Angola, who occasionally carry out activities of provision of services of any nature in Angolan territory or favor of entities with headquarters, effective management, or permanent establishment in Angola, irrespective of the place of delivery.

STROS is also applicable to transactions carried out between entities that have special relationships with each other, as defined in terms of the Large Taxpayers Statute, that is:

• when one has the power to exercise, directly or indirectly, a significant influence on the management decisions of the other, namely when the directors or managers of a company, as well as their spouses, descendants, and descendants, directly or indirectly hold not less than 10% of the capital or voting rights in the other entity.

Also included in STROS are cases when the majority of the members of the administrative, management, or management bodies are the same people or, being different people, are linked by marriage, de facto union, or kinship in a straight line;

• when the entities are linked using a subordination contract;
• when they are in mutual ownership or shareholding relationships, as well as linked using a subordination contract, peer group, or another equivalent effect under the terms of the Commercial Companies Act;
• when there are commercial relations between one and the other that represent more than 80% of its total volume of operations;
• when one finances the other in more than 80% of its credit portfolio.

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