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People

Eduardo Alberto da Costa Calú

Eduardo Alberto da Costa Calú

Managing Partner, SAL & Caldeira Advogados, Lda.

Eduardo Alberto Calú is the head of the tax practice at SAL & Caldeira and, since 2016, has served as the Managing Partner of the firm. Until recently he also led the labor practice of the firm. 

Eduardo has been deeply involved in the reform of the tax framework for the oil and gas and mining sectors in Mozambique, representing industry interests for many years. He delivers tax structuring and tax compliance advice and has developed and negotiated complex and robust tax opinions that have won the endorsement of the Mozambique tax authority.

He has extensive experience in all aspects of labor law and has assisted various clients in the management of strikes and other labor actions.

Experience has included advising:

  • A global top-10 leading oil company, in tax aspects related to a USD2.8 billion farm in transaction for their entry into a USD22 billion project
  • An expert witness before the arbitral court in London, in relation to tax implications under the Mozambican tax laws on a services agreement concluded between our client and a large mining company. Contract value: USD19 million
  • In tax litigation and obtaining a binding opinion for non-applicability of tax in Mozambique on dredging services in accordance with a double taxation treaty signed with Mozambique. Contract value: USD85 million
  • In tax aspects of a transfer of shares in a Mozambican company (a gas agent and distributor). We represented the sellers (non-resident taxpayers) before the tax authority in the application for a binding opinion on the tax treatment of the transaction, calculation of tax due and will proceed with the payment of the tax resulting from capital gains obtained by the direct transfer of shares and rights in the Mozambican company. Value of transaction: USD2 billion
  • A mining company, in a dispute with the tax authority regarding withholding tax on payments for services rendered outside Mozambique by non-resident entities. Contract value USD6 million
  • A mining company, in a dispute with the tax authority regarding corporate income tax. Value in dispute: USD2.2 million
  • In tax structure and tax-efficient planning, for companies aiming to invest in Mozambique in the mining and oil and gas business
  • A client in negotiations with the Mozambican government as regards the tax aspects for the LNG Project to be carried out in the north region of the country
  • An oil and gas company, in discussions with tax authorities regarding capital gains tax in connection with a farm-in to an EPCC. Contract value: USD2.64 billion
  • In the retrenchment of 113 employees in a Mozambican subsidiary of a UK-based company operating in Mozambique

Professional Qualifications

  • Lawyer, registered at the Mozambique Bar Association (2008)
  • University lecturer in criminal law (2006)

Education

  • Eduardo Mondlane University, Faculty of Law, Post-graduation in International Trade Law (2007 to 2008)
  • Eduardo Mondlane University, Faculty of Law, Law course (2000 to 2005) 

Recognition

  • Ranked as Leading lawyer in Chambers & Partners Global (2020)
  • Ranked as Leading lawyer in IFLR1000 (2020)

Prior Experience

  • Legal practice centre of the law, Faculty at Eduardo Mondlane University, providing legal assistance to indigent clients in civil, labor and criminal law
  • 2005 to 2006, Legal representative appointed by the 7th criminal section of judicial tribunal of the city of Maputo, to assist indigent people accused of crimes
  • 2005 to 2006, Legal Consultant, APIE – state real property administration agency

Memberships

  • Member of the Mozambique Bar Association