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Changes to the Corporate Income Tax Code

We hereby inform the business community and other interested parties that Law No. 12/2025 of 29 December has been approved, introducing amendments to the Corporate Income Tax Code, approved by Law No. 34/2007 of 31 December, and subsequently amended by Law No. 20/2009 of 10 September, Law No. 4/2012, of 23 January, Law No. 19/2013, of 23 September and by Law No. 20/2022, of 30 December (‘‘CIT Code’’).

Among the changes made, we can highlight the following: 

  • Permanent Establishment (PE):
    1. Reduction of the period for the creation of PE to 90 days for a place or a construction, installation or assembly site;
    2. The concept of PE is expanded to include the provision of services, including consultancy services, professional services, and other similar services, provided independently of physical presence, excluding digital services, when such services are rendered in Mozambican territory for a period or periods that, in aggregate, exceed 90 days within any 12-month period commencing or ending in the relevant fiscal year;
  • Income or gains:
    1. Income or gains are also those resulting from commissions obtained by intermediation agents in electronic money financial operations;
  • Digital services:
    1. Introduction of the definition of digital goods and services;
    2. Income from the transfer of goods or the provision of digital services will now be subject to withholding tax at the rate of 10%;
  • Capital gains:
    1. Capital gains are now taxed autonomously, at the rate of 32%.
  • Elimination of Special Corporate Income Tax Regimes: 
    1. The simplified bookkeeping and taxable income determination regimes have been discontinued, and taxpayers enrolled in these regimes must migrate to the organized accounting regime;
  • Commissions on electronic money transactions are now subject to withholding tax at the rate of 10%;
  • The obligation to withhold income tax on the IRPC now includes the date of recognition of the cost;
  • Commercial or civil companies in commercial form, cooperatives, public companies and other entities that carry out, as their main activity, a commercial, industrial or agricultural activity and those with a PE, are now required to organize their accounting records using electronic means, under the terms to be regulated.

The amendments are in force since January 01, 2026.