Transfer pricing in Angola

Transfer pricing in Angola at a glance

Regulation Type National regulations based on the OECD
Are there specific transfer pricing regulations? Yes
Submission deadline 30th of June of the following fiscal year
Submission deadline upon request N/A
Annual update required Yes
Official language requirements Portuguese
Potential impact of penalties N/A

 

Angolan tax law

Rules for transfer pricing in Angola are based upon:

  • Presidential Decree no. 147/13
  • Order no. 599/14
  • Circular nr. 12/DLT/DNI/2014

OECD

The transfer pricing regulations in Angola are generally in line and based on the OECD Transfer Pricing Guidelines. However, for the transfer methods the Angolan transfer pricing regulations deviate from the OECD. More about this can be found in the next section.

Methods

Accepted methods 

Accepted methods are:

  • the comparable uncontrolled price method
  • the resale price method
  • the cost plus method

Priority of methods

The Angolan transfer pricing regulations only allow the use of the traditional transfer pricing methods. This is the mayor difference between the OECD Guidelines and the Angolan transfer pricing regulations.

Documentation requirements

Information that should be included in the documentation:

In Angola only certain taxpayers need to submit documentation. If a company complies with one of the following characteristics, the company should submit documentation:

  • Taxpayers with an annual turnover (determined by amounts of sales and of provisions of services) equal to or greater than 7 billion Kwanza (approximately U.S. $70 million)
  • Taxpayers listed on the “major taxpayers” list
  • Taxpayers with activities in the financial, oil and gas, diamond, and telecommunication sectors or industries

If a company is obliged to prepare documentation the documentation should at least consist of the following:

  • Executive summary
  • Macroeconomic overview
  • Company description
  • Functional analysis
  • Identification of related-party transactions
  • Economic analyses of related-party transactions

Language

Rules for transfer pricing in Angola prescribe that all documentation should be submitted in Portuguese. 

Requirements to prepare documentation annually

Rules for transfer pricing in Angola prescribe that the documentation should be updated annually and that the documentation should be submitted no later the 30th of June of the following fiscal year.

Submission deadline upon request by tax authorities

Not applicable.

Advance Pricing Agreements

General

In Angola it is not yet possible to obtain Advance Pricing Agreements. However, the transfer pricing regulations are developing so in the future this might change.

Terms 

Not applicable.

Penalties

In Angola there are no specific transfer pricing penalties in place, this means that ordinary penalties apply. However, they are currently working on a new General Tax Code and it is expected that this new Code will have specific transfer pricing penalties. When the new Code will be enacted, however, remains unclear.

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