General State Budget 2024

• Published date: 05 February 2024
• Subject Matter: Corporate/Commercial Law, Government, Public Sector, Tax, Corporate and Company Law, Income Tax, Fiscal & Monetary Policy, Withholding Tax
• Law Firm: PLMJ
• Author: Mr PLMJ

Law 15/23 of 29 December approving the General State Budget for the financial year 2024 ("GSB 2024") was published and entered into force on 1 January 2024.

The main tax measures introduced by the GSB 2024 are:

1 SPECIAL CONTRIBUTION ON FOREIGN EXCHANGE OPERATIONS ("CEOC"):

The GSB 2024 has created the Special Contribution on Foreign Exchange Transactions (Contribuiç'o Especial sobre Operaç'es Cambiais - "CEOC") and established the legal rules applicable to it. The main features of the CEOC are:

• Individuals and legal entities domiciled or incorporated in Angola that request a financial institution to make a transfer abroad under contracts for the provision of services, technical assistance, consultancy and management, capital operations and unilateral transfers are subject to payment of the CEOC.
• Transfers intended to cover health and education expenses, when made directly to the bank accounts of health or education institutions, are excluded from the scope of payment of the CEOC.
• Transfers of dividends or repayments of borrowed capital including interest, are also excluded from the scope of the CEOC.
• The rate applicable to the value of each transfer is (i) 2.5% for individuals; and (ii) 10% for legal entities.
• The basis of calculation is the amount to be transferred in Angolan currency at the exchange rate in force at the time of the transfer. The financial institutions must assess and pay the CEOC when the transfer is processed. They must also ensure that the special contribution is remitted to the General Tax Administration.
• The State and all its organisations, with the exception of public institutions and companies, diamond companies and oil investment companies, are exempt from paying the CEOC.

1. CHANGES TO THE INDUSTRIAL TAX CODE

These are the main changes to the Industrial Tax Code (Corporate Income Tax Code):

• Changes in the value of assets and capital gains or losses resulting from the revaluation of fixed assets - tangible fixed assets, intangible fixed assets and investments in real estate - to fair value will be considered tax neutral with effect from the tax year 2023 and will not be considered as income or expenses for the purpose of determining the Industrial (Corporate) Tax base.
• The depreciation charge for the year on fixed assets, in the part resulting from the revaluation, over the useful life of the asset will not be recognised for tax purposes and will be subject to compliance with accounting rules. This includes the separation...