Tax
IRPC at 32 per cent with 16 per cent IVA and dedicated extractive regimes
Corporate income tax (IRPC) is charged at 32 per cent, one of the higher rates in the region, with IVA at 16 per cent. Mining and petroleum operations pay production taxes and are subject to a separate fiscal regime, including capital-gains rules that were tested in the high-value LNG participation transfers.
Key rules
- Jurisdiction — The Autoridade Tributária de Moçambique assesses; objections and then appeals to the fiscal courts.
- Deadline — IRPC return: by 31 May following the calendar year
- Deadline — IVA return: monthly by the last day of the following month
Governing law
- Código do IRPCLei 34/2007, as amended
- Código do IVALei 32/2007, as amended
- Lei do Regime Específico de Tributação para a Actividade MineiraLei 28/2014
In practice
Capital gains on indirect transfers of extractive interests are the defining Mozambican tax issue: the state has assessed very large sums on offshore share transfers affecting Rovuma-basin rights, and the statutory basis for taxing those indirect disposals is the point on which such assessments turn.