Law no. 9/19 was published and entered into force last April 24 and introduced several amendments to the Personal Income Tax Code, which need to be timely and adequately dealt with.

From the amendments introduced to the Personal Income Tax Code, we understand the following should be highlighted:

• Distribution of profits in favour of owners of civil companies, with our without the commercial form, are now subject to Personal Income Tax and are included in Taxation Group A – Article 1, paragraph f) and Article 3, no. 2, paragraph d);
• Bonuses for the end of career, due under the legal-labour relationship, are no longer excluded from Personal Income Tax – Article 1, paragraph b);
• The non-subjection monthly limit of AKZ 30,000 is now applicable, individually and independently, to daily food allowances and daily transportation allowances attributed to dependent workers – Article 2, paragraph k) and n);
• Income obtained by members of the governing bodies of companies are now included in Taxation Group A (prior included in Taxation Group B), with the consequent application of the progressive Personal Income Tax rates (instead of the single rate of 15%) – Article 3, no. 2, paragraph c);
• Clarification of the taxation mechanism of taxpayers included in Taxation Group B and Taxation Group C, depending on such taxpayers having (or not) organized accounting – Article 8, no. 3 and 4 regarding Taxation Group B and Article 9, no. 6 and Article 10, no. 3, paragraph b) regarding Taxation Group C;
• The list of professions included in Taxation Group B is extended to include hairdressers, masseurs and disc jockey – Table referred to in Article 3, no. 3 attached to the Personal Income Tax Code;
• Republication of the “Minimum Profits Table” applicable to Taxation Group C taxpayers – Table referred to in Article 16, no. 1 attached to the Personal Income Tax Code;
• The deadline for the payment of the tax due by taxpayers included in Taxation Group C that do not have organized accounting is postponed to March of the following year (instead of February) – Article 11, no. 3, paragraph a);
• Introduction of a tax neutrality regime, for Stamp Tax and Real Estate Transfer Tax, applicable to the transfer of real estate property by an individual merchant that is direct and exclusively used in the context of its business activity in benefit of a company to be incorporated by the later;

Such tax neutrality is dependent on the verification of certain requisites, namely that (i) the company benefiting from the real estate property transfer is held in 90% by the said individual merchant and (ii) the remaining shareholding are held by its spouse or straight-line first degree relative;

The application of the tax neutrality is also dependent of authorization of the head of the Angolan Tax Authorities AGT – Article 2 of Law no. 9/2019, dated April 24.

To access the relevant Law, please refer to the attached document.