The new Personal Income Tax Code (“IRPS”) was put out for public consultation on 1 April 2025, with the aim of collecting contributions from entities representing civil society, the business sector and professional associations by 30 April 2025 (Circulares | Portal da Administração Geral Tributária).
This proposal is part of the effort to modernize the Angolan tax system and aims to replace the current taxation model based on multiple legislation, such as the Employment Income Tax Code (“CIRT”), the Capital Investment Tax Code (“CIAC”), the Stamp Duty Code (“CIS”) and the Property Tax (from the rental income perspective), with a single tax that covers all income of individuals.
In summary, the IRPS Code, in the version now proposed, provides for a paradigm shift in the taxation of individuals, with the following most relevant aspects standing out:
- Resident and non-resident individuals in Angola will be subject to IRPS;
- A worldwide income taxation model will be adopted for tax residents in Angola, and territorial taxation (income from Angolan sources) for non-residents, with the implications that may arise with regards to possible international double taxation and the need to eliminate it;
- Tax residency in Angola will be assessed based on the individual's stay in Angolan territory (it is sufficient that they remain there for more than 90 days, consecutively or not, in any 12-month period starting or ending in the year in question), with potential situations of dual residency conflicts in situations of international mobility;
- IRPS will be levied on various types of income, classified into five categories: income from employment (category A); business and professional income (category B); investment income (category C); income from real estate (category D); wealth increase, including capital gains (category E) and, with regards to income from employment, tax will now be due over typified benefits in kind (e.g., use of a vehicle, housing);
- As a rule, the tax withheld at source when income is paid will be deemed as a payment on account, with the final tax being calculated, by aggregating the overall income received, at marginal rates of up to 25% (with the exception of investment income subject to withholding tax at source at the final rates of 10% or 15%), with the possibility of deducting some expenses (e.g., health and education);
- Resident taxpayers who obtain income from foreign sources in countries with which Angola has signed an agreement to eliminate double taxation (currently, Portugal, China and the United Arab Emirates) will be entitled to a tax credit for international double taxation;
- With the exception of individuals who only receive income from employment paid by a single employer entity in Angola, there will be an overall obligation to submit an annual income tax return.
Given the significant impact of this reform on personal taxation, KPMG is fully aware of the practical implications of the proposed changes in the context of domestic and international taxation, providing its contribution within the scope of this public consultation, and is most available to clarify or provide the necessary support in anticipation of these changes.