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Tax Controversy and Disputes

Our tax controversy lawyers in Mozambique focus on complex tax controversy matters, including: tax audits, administrative appeals, claims for refunds, voluntary disclosures and civil tax litigation as well as criminal tax matters.

We represent multinational corporations, privately-owned companies, partnerships, limited liability companies, high-net-worth individuals and trusts and estates in all aspects of sophisticated tax controversies and criminal tax matters.

Experience has included advising:

  • A large mining company in an appeal against the applicability of 1% tax flat rate to deduct from gross receipts from invoicing to the tax authority.
  • An international engineering, procurement, construction management, and operations service company, as an expert witness under arbitration in the International Chamber of Commerce (ICC) of London in relation to tax implications under the Mozambican tax laws on a services agreement concluded between our client and a large mining company with operations in Mozambique.
  • A dredging company, in a tax litigation case in respect of dredging contract to develop the Maputo port and the applicability of local law versus the double taxation agreement entered into between Mozambique and the United Arab Emirates.
  • A mining company, in a tax dispute (pre-litigation and litigation) related to the applicability of the double taxation treaty entered into between Mozambique and the United Arab Emirates.
  • A global advertising company in a tax dispute before the tax authority on VAT and corporate income-related issues.
  • A large agricultural international company in a tax dispute regarding corporate income tax.
  • A global services provider of the US government in a customs dispute involving 16 special vehicles that were in transit in Mozambique.
  • A large mining company in a tax dispute related to capital gains arising from the issuance of new shares. In this case the tax authority’s initial interpretation was that it was not an issuance of shares but rather an indirect sale of shares.
  • A leading African cement supplier, in a tax dispute (pre-litigation and litigation) related to accounts procedures adopted in relation to cement imports.