It was recently released by the Angolan Tax Authorities (AGT) the Instruction n.º 047/GJ/AGT/2022, on the provisional assessment and payment of the CIT of the current year. Besides what we already have mentioned in our latest NewsFlash, we would like to highlight the following aspects referred in the Instruction:

i. In the same is referred that the provisional payment is due on services, including the ones that by its nature are not liable to withholding tax, that have not been liable to such withholding tax. As such, being clear in the Law that only the services that are not liable to CIT withholding tax as provided in number 13 of article 67 of the CIT Code should be liable to the provisional payment, it is not clear if AGT intends to extend such liability to the services that for other reasons, where not liable to withholding tax, for example services rendered to CIT exempt entities, or foreign entities.

ii. It is provided that the taxpayers that have presented a loss in the last year should, although being exempt of payment of the provisional payment, must submit the provisional return until the last working day of August. Regarding this point,

a) Once again it is not clarified if the loss to be considered should be the tax or accounting one. Therefore, due to the different interpretations on this matter, even within AGT, we advise the taxpayers to seek clarification near AGT if on their specific situations (namely when the accounting result is different of the tax one) they should proceed with the payment of the provisional tax

b) The return above referred is submitted electronically and it is available on AGT Portal (“Portal do Contribuinte”). We believe that the same is prepared for the specific situation referred by AGT, eg submission without payment