Global Mobility Services: Taxation of International Assignees - Angola

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www.pwc.com/ao/en Global Mobility Services: Taxation of International Assignees - Angola Taxation issues & related matters for employers & employees 2017

Last Updated: February 2017 This document was not intended or written to be used, and it cannot be used for the purpose of avoiding tax penalties that may be imposed on the taxpayer.

Country: Angola Introduction: International assignees working in Angola 4 Step 1: Income tax summary 5 Step 2: Rates of tax 10 Appendix A: Contacts and offices 11 Additional Country Folios can be located at the following website: Global Mobility Country Guides Global Mobility Country Guide (Folio) 3

Introduction: International assignees working in Angola PwC is the world's leading provider of professional services. The People and Organisation group works together with its clients to find solutions for the challenges they encounter when transferring people from one country to another. This summary is intended to inform foreign nationals and their employers about high level tax, social security and immigration issues. This guide is not exhaustive and cannot be regarded as a substitute for professional advice addressing individual circumstances. Nevertheless, answers will be found to most of the questions raised by an expatriate or his/her employer. More detailed advice should be sought before any specific decisions are made about these issues. More information can be obtained from our offices specializing in People and Organsaition Services, Global Mobility. 4 People and Organisation

Step 1: Income tax summary Question Basic information Answer 1 The date of the tax year end 31 December 2 Types of income that are liable to tax Taxable employment income comprises any remuneration paid in cash or in kind to an individual in the form of regular or incidental wages, salaries, bonuses, premiums, entertainment and travel allowances, subsidies, rewards, directors' fees, in respect of dependent or independent services, irrespective of the source, place, currency and form stipulated for its calculation and payment. 3 How are residents and non residents treated differently for tax purposes? 4 Do spouses file tax returns jointly or as individuals? 5 Method of determining domestic tax residence 6 Provide some details of the exchange controls in this jurisdiction Interest, dividends and rental income sourced in Angola are liable to tax. There is no difference of treatment between residents and non-residents. There is no filing requirement in Angola for individuals. The General Tax Code establishes a definition of tax residency criteria for individuals - individuals, who stay in Angola for more than 183 days during a twelve-month period, will become tax resident in Angola. There are no tax information exchange agreements in place in Angola. Global Mobility Country Guide (Folio) 5

Question Tax rates, allowances and credits Answer 7 Income tax rate Progressive PIT rates with a maximum of 17% (17% marginal rate applies on income earned in excess of AKZ 230,000). For calculation purposes, the employer applies the rates to the gross (taxable) income less the social security contribution paid by the employee, if applicable. 8 Income tax allowance amount Nil. 9 Capital gains tax allowance amount Not applicable. 10 Rate of capital gains tax Capital gains are liable to Investment Income Tax (IAC), at a 10% tax rate. Please note that, there are no clear compliance/payment rules in force for the taxation of capital gains at the individuals level. 11 Rate of tax on interest Interest on loans granted by third parties to individuals is liable to IAC, at a 15% tax rate. 12 Rate of tax on dividends Dividends paid by an Angolan entity to individuals are liable to IAC, at a 10% tax rate. 13 Rate of employer social security 8% of gross salary. The employer is required to withhold the employee s contribution and pay both contributions by the 10th day of the month following the month in which the personal income was paid. 14 Rate of employee social security 3% of gross salary. According to the Angolan Law, unless employees can prove that they are covered by a social security regime in their home country, which provides for protection comparable to that of the Angola social security system, all employees must register with the National Social Security Institute and contribute to it. Please note that the Angolan National Social Security Institute is refusing to register expatriate employees holding valid work visas. 15 What types of income are exempt from tax/deductible from taxable income? Holidays and Christmas allowances up to a limit of 100% of employees basic salary, housing allowances up to the limit of 50% of the value of the rental agreement, social allowances (e.g. family allowance to the limit of 5% of the employee s monthly basic salary, maternity, death, and labour accidents) and old-age, disability and survivor s pensions, retirement bonuses, social security contributions, severance payments (up to a maximum ceilings as foreseen in the labour law). Meal and transport allowances are not subject to PIT up to a total limit of AKZ 30 000 per month. 6 People and Organisation

Question Before arriving in the country 16 What must an individual do in order to be able to work in the country ie obtain a work permit, intra company transfer visa, critical skills visa 17 What conditions must be met to be eligible to have a work permit 18 What is the maximum period a work permit will be issued for Answer Obtain a work or residence visa. Work visas obtainment may be divided in 2 main phases: (i) obtainment of the favourable opinion for the hiring of a foreign citizen issued by the Ministry in charge for the sector of activity in which the hiring company operates and (ii) submission of the visa application with the Angolan Consulate at the country of origin / residency. In addition, the employment agreement of foreign employees must be registered in the employment center of the area where the company operates and the request must be submitted up to 30 days after the starting date of the professional activity. There is no maximum period. Work visas may be granted for the duration of the employment agreement (freely agreed) and its renewals (maximum twice), under the terms agreed between the employer and the employee. 19 Can a work permit be renewed Yes. We refer to our comments on question 18. 20 What would be the immigration requirements for a short term business visitor 21 At what point/type of activity would trigger a tax liability in the country For business development purposes eg. to attend business meetings or business workshops -, it is possible to apply for an ordinary visa, which is usually granted for a time period of 30 days, renewable locally for 2 times. Please note that an ordinary visa does not allow its holder to undertake any remunerated activity in Angola or to apply for a residence permit. Tax liability is triggered when the income is paid for or borne by an Angolan employer. For these purposes, please note that foreign individuals should hold a valid work visa. A forein entity is deemed to create a Permanent Establishment (PE) in case it carries out services in Angola through employees for a period of at least 90 days in any given period of 12 months. Consequently, the foreign entity will be subject to Angolan taxation (eg. Corporate Income Tax at a rate of 30%, etc). Global Mobility Country Guide (Folio) 7

Question During the assignment 22 Does an individual need to register as a taxpayer 23 Timeline and process for registering as a taxpayer 24 Are provisional taxes required? No Answer 25 If yes, on which dates? Not applicable 26 If yes, what are the penalties for non compliance? 27 Important dates to remember during the tax year At the end of the tax year Tax registration will only be required in case the foreign employee has a work or residence visa Companies have to register employees with the competent authorities at least 30 days before starting activities. The registration of employees should be made in the first month of employment Not applicable Not applicable 28 Tax return filing deadline Angola applies a fairly straightforward Pay-As-You- Earn (P.A.Y.E.) system, hence there are no Personal Income Tax returns filed by the employees. All the obligations must be fulfilled by the employer through the monthly withholding tax mechanism, i.e., withholding tax is final. 29 Penalty for late filing Not applicable 30 Tax payment deadline The Angolan employer must file every month a tax return disclosing the remuneration and fees paid to employees and the tax withheld. Tax is payable simultaneously with the return filing, which deadline is by the end of the following month 31 Penalty for late payment Penalty of 35% of the tax due plus late interest (1%) the 35% rate can be reduced to 30% in case of voluntary payment At the end of an assignment 32 The process and actions required before leaving the country Other comments Before leaving Angola there are no specific actions to be taken. Work visa needs to be cancelled by the employer after the employee has departed. Angola does not have any double taxation treaties with any country. No foreign credit system exists as the PAYE system is final. This applies regardless of how long the assignment will be in Angola. 8 People and Organisation

Step 2: Rates of tax Personal income tax rates for 2017 (in Angolan Kwanza) Over Up To Marginal Rate Marginal Tax Accum. Total Accum Total to Last Band 0 34.450 0,00% 0 0 0 0 Excess amount 34.451 35.000 0,00% 550 550 0 34.450 35.001 40.000 7,00% 350 900 550 35.000 40.001 45.000 8,00% 400 1.300 900 40.000 45.001 50.000 9,00% 450 1.750 1.300 45.000 50.001 70.000 10,00% 2.000 3.750 1.750 50.000 70.001 90.000 11,00% 2.200 5.950 3.750 70.000 90.001 110.000 12,00% 2.400 8.350 5.950 90.000 110.001 140.000 13,00% 3.900 12.250 8.350 110.000 140.001 170.000 14,00% 4.200 16.450 12.250 140.000 170.001 200.000 15,00% 4.500 20.950 16.450 170.000 200.001 230.000 16,00% 4.800 25.750 20.950 200.000 230.001 17,00% 25.750 230.000 Global Mobility Country Guide (Folio) 9

Appendix: Contacts and offices Contacts Luis Andrade Tax Director Rita Ramos Manager Tel: +244 227 286 109 Tel: +244 227286 109 Email: luis.p.andrade@ao.pwc.com Email: rita.ramos@ao.pwc.com 10 People and Organisation

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