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
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.
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.
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
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
Advance Pricing Agreements
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.
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.