We hereby inform the business community and other interested parties that Law No. 11/2025 of 29 December has been approved. It introduces amendments to the Personal Income Tax Code, approved by Law No. 33/2007 of 31 December and subsequently amended and republished by Law No. 19/2017 of 28 December (IRPS Code).

The main changes introduced include the following:

i) The physical presence in the country (more than 180 days) is removed as a criterion for determining tax residency.

ii) The concept of tax resident is expanded to include individuals who:

• Maintain their main residence in Mozambique;
• Perform their professional activities in Mozambique, whether remune­rated or not, unless they can prove the activity is secondary;
• Have the center of their economic interests in Mozambique;
• Are crew members of ships or aircraft, provided that they are in the service of entities with residence, head office or effective management in Mozambican territory;
• Nationals who perform their duties or are on assignment in a foreign country and are not subject to income tax on their total income in that country.

iii) The scope of taxable income in Mozambique is expanded to include gains from the transfer of goods and the provision of digital services performed or used in Mozambique, when payable by entities located or resident in Mozambique.

iv) clarification that income subject to autonomous taxation shall not be aggregated for tax purposes.

v) Commissions earned by electronic money agents and income from the transfer and provision of digital services by non-residents (or where the debtor is not an IRPS taxpayer) and digital services provided to IRPS taxpayers are taxed at a final withholding rate of 10%.

vi) Withholding tax on IRPS becomes mandatory at the time of recognition of costs; withholding tax procedures for digitally-sourced income and commissions still pending clarification through regulations.

vii) Holders of second-category income shall maintain organized accounting.

viii) A new autonomous regime for capital gains has been introduced under Article 54-A,: