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Global Mobility Services: Taxation of International Assignees - Mozambique

Taxation issues &

related matters for

employers &

employees 2017

http://www.pwc.com/mz/en/index.jhtml

Last Updated: June 2017

This document was not intended or written to be used, and it cannot be used, for the purpose of avoiding tax penalties that may be imposed on the taxpayer.

Global Mobility Country Guide (Folio) 3

Country: Mozambique

Introduction: International assignees working in Mozambique

4

Step 1: Understanding basic principles 5

Step 2: Understanding the Mozambique tax system 6

Step 3: What to do before you arrive in Mozambique 10

Step 4: What to do when you arrive in Mozambique 15

Step 5: What to do at the end of the tax year 16

Step 6: What to do when you leave Mozambique 17

Appendix A: Rates of tax 18

Appendix B: Double-taxation agreements 19

Appendix C: Mozambique contacts and offices 20

Additional Country Folios can be located at the following website:

Global Mobility Country Guides

http://www.pwc.com/us/en/hr-international-assignment-services/publications/index.jhtml

4 People and Organisation

Introduction: International assignees working in MozambiquePwC is the world's leading provider

of professional services. The People

and Organisation group works

together with its clients to find

solutions for the challenges they

encounter when transferring people

from one country to another.

This brochure is intended to inform

foreign nationals and their

employers about tax, social

security and immigration issues

in Mozambique.

This guide is not exhaustive and

cannot be regarded as a substitute

for professional advice addressing

individual circumstances.

Nevertheless, answers will be found

to most of the questions raised by

an expatriate or his/her employer.

More detailed advice should be

sought before any specific decisions

are made about these issues.

More information can be obtained

from our offices specializing in

People and Organisation, Global

Mobility (see Appendices).


Step 1: Understanding basic principles

The scope of taxation in Mozambique

1. A foreign national working in

Mozambique will, in general,

become liable to Mozambique

income tax.

The tax year

2. The tax year for individuals

covers the period to

31st December.

Determination of residence

3. Individuals are considered tax

resident in Mozambique in any

given fiscal year if they remain

in the country for more than

180 days, continuously or in

aggregate, or if they stay for less

time, possessing a residence in

the country and are deemed to

have the intention to use it as

place of habitual residence.

4. A person will also be considered

resident for tax purposes if

he/she is a crewmember of a

ship or an aeroplane, provided

the services are rendered to an

entity with residency,

headquarters or effective

management in Mozambique.


Step 2: Understanding the Mozambique tax system

Taxation of resident vs non resident individuals

5. It is very important to

determine an individual’s

tax residence position in

Mozambique as this

determines the scope and

extent of Mozambican tax.

6. Individuals are liable to pay

individual income tax on –

a. a worldwide basis, if

considered residents for

tax purposes;

b. income earned in

Mozambique (paid by

a resident entity) or

deriving from

Mozambique, if

non-residents.

7. In the case of residents, the

worldwide basis concept

means that these individuals

are liable to declare all

income, whether earned in

Mozambique or from other

external sources.

Remuneration for services performed

8. Non residents are taxable on

Mozambican source

remuneration. They are

generally not taxed on non

Mozambican remuneration

unless this remuneration is

in respect of duties

performed inside of

Mozambique.

9. Residents are taxable on

worldwide remuneration,

subject to the provisions of

relevant Double Tax

Agreements (DTAs) and tax

relief for foreign tax paid on

foreign source income.

Interest income


Mozambican source interest

income only.


worldwide interest income


DTAs and tax credit relief

under domestic legislation.

Dividends


Mozambican source

dividend, income only.


overseas dividend income




Rental income


Mozambican source rental

income only.


worldwide rental income




Capital gains


capital gains arising from

the disposal of:

– Immovable property

located/situated in

Mozambique (including

direct and indirect

interest in such

property);

– Assets of a permanent

establishment through

which a trade is carried

on in Mozambique; and

– Shareholding on

Mozambican companies.



capital gains arising on the

actual disposal of

worldwide assets.

Employment income

18. The Mozambican Tax

regulations define as

employment income all

economic advantages that

arise for the employee by

virtue of an employment

relationship. These

economic advantages shall

include payments, salaries,

wages, earnings, rewards,

percentages, commissions,

allowances or bonus,

attendance fees,

emoluments, participation

in penalties/fines, other

accessory remunerations

and any type of

remuneration in general,

earned by employees.

Source of employment income

19. Non-resident employees will

be taxed on employment

income derived from a

Mozambican source,

irrespective of where, when

and by whom it is paid.

As a general rule, the source

of employment income is

where the relevant

employment has

been rendered.

20. Where a non-resident

individual is employed by a

non Mozambican employer

and that employer requires

the employee to render

services both inside

Mozambique and abroad,

only that portion of the

remuneration attributable to

the services rendered inside

the country will be

considered from a

Mozambican source and

taxable in Mozambique.

21. However, when the taxpayer

is resident in Mozambique

he/she will be subject to tax

on his/her worldwide

employment income, subject

to relief by virtue of the

DTAs in force (currently

with Italy, Portugal,

Mauritius, South Africa,

United Arabian Emirates,

India, Macau, Vietnam, and

with Botswana).

Structuring remuneration packages

22. Remuneration packages can

be structured in a tax

efficient manner as well as

potentially reducing the cost

of employment. The

structure should take into

account the policies and

procedures of the

international assignment

policy of the employer.

23. The following benefits and

allowances may be adopted

in a remuneration package:

– Attribution of

company’s car

– Meal allowance

– Per diems

– Employer contributions

for mandatory and

optional social security

regimes

24. A PwC tax specialist can

assist you in creating a tax

efficient remuneration

package.

Taxation of investment income

Interest

25. There is Mozambican

withholding tax (10% for

individuals) on interest on

fixed term bank deposits.

Dividends

26. Dividends from a

Mozambican source are

taxed through withholdings

at a 20% tax rate.

Other investment income

27. For non-residents, all other

investment income is

generically taxed at a rate of

20% (final taxation).

Rental Income

28. Rental income will generally

be fully taxable if the income

arises from a Mozambican

source. The general rule is

that the source of rental

income is located where the

relevant property is located.

29. Rental income is taxed at a

marginal tax rate of 32%.


30. Expenses (such for example

with conservation and

maintenance) are accepted

as deduction on the gross

rental income.

Capital gains

31. Tax on capital gains is

applicable on:

– Onerous transfer of

rights regarding

immovable property and

similar acts;


shareholding and

other securities;

– Onerous selling of

intellectual and

industrial property and

know-how;


contractual positions or

other rights inherent to

contracts regarding

immovable property;

– Net income from

operations regarding

financial instruments.

32. With regards to tax on

capital gains, there are two

specific situations

to consider:

– Only 50% of the positive

or negative balance

resulting from the

onerous transfer of

rights or contractual

positions regarding

immovable property and

intellectual and

industrial property,

including know-

how; and

– With regards to gains or

losses resulting from the

onerous transfer of

shareholding, the

percentage of the value

to be considered for tax

purposes is proportional

to the time the taxpayer

has held the

shareholding, namely:

o 100% of value if held

for up to 12 months


between 12 and

24 months


between 24 and

60 months


for more than

60 months

Exchange control

33. According to Mozambique

exchange control

regulations, transfers of

money abroad related to

current transactions (not

capital) do not require

previous authorization from

the Central Bank, however

must be registered before

the commercial bank based

on the required supporting

documents (e.g., for

payments of services, by a

contract, or for payments of

goods, by the

import documents). Capital

transactions with abroad

(such as foreign direct

investment and external

loans) require previous

authorization from the

Central Bank, who also

approves the respective

terms and conditions.

34. Foreign nationals are free to

purchase residential property,

except for some immovable

assets, and subject to Central

Bank’s prior approval to import

the funds to Mozambique for

such purpose. Foreign nationals

in possession of valid work or

resident permits in Mozambique

may borrow funds locally, only

subject to bank risk assessment

and banking practice

Customs and temporary residents

35. Foreign nationals working in

Mozambique temporarily or

on a contract basis may

import personal effects free

of customs duty and VAT

into the country provided

they are duly granted with a

resident permit and comply

with some specific

requirements (e.g. in case of

importation of vehicle, it has

to be held by the worker for

a period exceeding 6 months

to be imported under this

regime). These include

household furniture and

effects and other movable

articles, equipment

necessary for the exercise of

a calling, trade or profession,


television and hi-fi sets and

other household appliances.

All of these items must be

for personal use only, and

must not be disposed after

the date of entry. These

goods may not remain in

Mozambique on a

permanent basis and must

be returned overseas upon

departure from

Mozambique, unless the

person obtains permanent

resident status or citizenship

in Mozambique.

34. In order for foreign

nationals to benefit from

importation of personal

effects free of customs duty,

it is necessary to submit an

application to the Customs

Authorities, requesting such

exemption and the foreign

national have 30 days to

submit the respective

application.

35. Pets may not enter

Mozambique, unless a

permit has been issued by

the competent authorities.

Employees' tax

36. Employee’s tax is income tax

and employer must withhold

from the remuneration paid

to an employee, and pay

over to the Tax Authorities.

All employer paying

remuneration have an

obligation to account for

employees’ tax. Penalties

and interest are imposed by

the Tax Authorities if the

employees’ tax is not paid

timeously. Employees' tax is

assessed as follows:

37. The employer withholds

most of the individual

employment income at the

time of payment of the

amounts at rates established

in the law considering the

monthly gross amounts

received and the family

specific circumstances. Such

rates vary from 0% to 32%.

38. The only exception to the

monthly withholdings is

gratifications paid by a

different entity, which must

be declared by the employee

in his/her yearly tax return.

The payment of the income

tax regarding this benefit is

due at the end of the tax

year, with the submission

of the annual tax return by

the employee.

39. All allowances and subsidies

paid to the employees must

be added to his/her fixed

monthly remuneration and

considered as a whole for the

determination of the

monthly tax rate applicable.

40. For this purpose, companies

are obliged to issue, with

respect to every employee, a

declaration comprising the

total amounts of

remuneration (cash plus

fringe benefits) paid along

the tax year. This declaration

must be issued in duplicate

up until the 20th January of

the following year and one

copy must be delivered to

the employee and the other

to the Tax Authorities.

Social Security

41. The employer is subject to

social security contributions

at a rate of 4% over the

salary of each employee.

Deductions, Credits and Allowances

Inheritance and Donation Tax

42. Inheritance and donation

tax is levied on the transfer

of movable and immovable

assets. The tax is levied on

the person that has acquired

the asset.

43. The tax rate is 2% for

descendants, spouses, and

ascendants, 5% for siblings

and relative in a direct line

and up to the third degree,

and 10% for other people.

44. In the event of death or

presumed death, the

beneficiaries are required to

report such an event to the

tax authorities declaring the

value of the transferred asset

and the acquisition title.


Step 3: What to do before you arrive in Mozambique

45. Mozambique restricts work

related immigration using a

quota system. Any foreign

employees above this quota

would only be allowed when

bringing in critical skills that

will be passed to the local

population.

Short term

46. For foreign nationals travelling

to Mozambique for business, a

business visa is required. This is

valid for 30 days (renewable for

more 60 days).

47. This visa is not suitable for

individuals who wish to have a

regular work pattern in the host

country but merely look to

attend meetings, seminars,

conferences, etc.

48. However, for those that, for

example, will receive or deliver

short-term training, a short

term work permit is required.

Short Term Work Permit is

granted for ninety days

consecutive or interpolated

and cannot be renewed;

Short Term Work Permit’s

processing fees will amount to

one minimum wage of the

company’s sector of activity.

49. Individuals need to apply for a

business in their home country

before arriving in Mozambique

and for the case of business and

work visa, the applications must

also be submitted previously at

Migration Services for their

knowledge of the

application process.

50. Passports must be valid for a

minimum of 6 months on entry

into Mozambique.

51. There are 2 types of business

visas that can be applied for

before travelling to

Mozambique:

– 30 days business visa

– 3 months multiple

business visa – this visa is

issued to the traveller for

90 days. However, it only

allows the individual to

stay in Mozambique for

30 days per visit. The

traveller will have to leave

the country after 30 days

and return to his country

of origin and he/she is

then allowed to re- enter

Mozambique for another

30 days.

52. Should the traveller need to

work in Mozambique for over 6

months then he/she will have to

apply for a long term

work permit.

Long term

53. For longer term posts a work

permit is required.

Contracting foreign employees

54. All foreign nationals wishing to

work in Mozambique must

apply for a work permit before

their arrival. Subsequently, they

will be able to apply for the

work visa and resident permit

for themselves and for the rest

of the family that will be

accompanying the individual,

as well.

55. Employers will need to act as a

sponsor for the individuals’

work permit and residence

permit and the employee must

submit a signed and approved

employment contract prepared

by that sponsoring company.


56. Work permits are issued for up

to 2 years at a time and must be

kept valid at all times. They are

issued specifically for the

company and position of the

employee and are not

transferable. Resident permits

are issued for a period of 1 year

and should be renewed

annually.

57. Please remember that you and

any accompanying family

require entry permission and

appropriate permits to enable

you and your family to reside in

Mozambique. Permits must be

kept valid at all times. Work

permits are issued according to

certain conditions.

In principle, companies

incorporated and branches

registered under the laws of

Mozambique

("Mozambican companies")

may only contract

expatriates to work or

render services in

Mozambique through the

following 4 (four) main

procedures, namely:

a. Communication of

employment;

b. Work permit;

c. Temporary work

declaration of 90 days

(Short Term Work Permit);

and

d. Temporary work

declaration of 180 days

(Short Term Work Permit

for Oil and Gas Sector)

Communication of employment

58. Depending on the type of

classification of the companies

(i.e, small, medium or large),

Mozambican companies or

branches may have expatriates

at their service, without

requiring any approval or

authorization from the

government and, specifically,

from the Labour authorities.

This possibility is only available

if one of the two conditions

mentioned below are

met, namely:

– If the expatriate to be

employed is under the

quota established by law

("Condition 1"); or

– If the investment project of

the company approved

exceptionally by the

Ministry of Labour grants a

higher quota for expatriates

("Condition 2").

Condition 1

59. First and foremost, it is crucial

to note that the following

quotas are available for

expatriates, depending of the

classification of the company -

– 5% of the total number of

employees, if large-

sized companies;

– 8% of the total number of

employees, in medium-

sized companies;

– 10% of the total number

of employees, in

small-sized companies.

It should be noted that small businesses, even if the total number of national workers is less than ten, they can still contract one foreign employee. .

Procedures

60. When proceeding with the

communication of employment,

employers should give notice of

the employment to the

Provincial Directorate of

Labour of the geographical area

where the head office of the

company is located;

61. To the said notice, the following

documents must be attached -

a. The certificate of

equivalences (of the

qualifications obtained

abroad) issued by the

Ministry of Education

in Mozambique;

b. Company declaration

of the total number of

employees (nationals

and foreigners) –

“Relação Nominal” of

the previous year;

c. Social Security

Clearance certificate,

attesting that there is

no outstanding

amounts owed to the

Social Security System

- In order to obtain

such certificate, it is

necessary to submit an

application to the

Social Security

authorities requesting

the issuance of

such certificate;


d. Tax Clearance certificate,

attesting that there is no

outstanding amounts owed

to the Tax Authorities - In

order to obtain such

certificate, it is necessary to

submit an application to the

Tax Department requesting

the issuance of

such certificate;

e. Bank slip proving the

payment of the

administrative fees 5

minimum wages of the

company’s sector of

activity);

f. Three copies of the

employment contract,

which the duration cannot

exceed 24 months ;

g. Certified copy of the

Passport of the employee;

h. Operating license of the

company.

62. Please note that the same

conditions apply to (i) legal

representative, (ii)

shareholder(s) with

management powers, (iii) any

other person with a power of

attorney to represent the

company or (iv) staff;

63. Differently the same condition

does not apply for the Oil & Gas

legal representative,

shareholders(s) with

management powers. On these

cases, instead of a valid work

contract, they should only

attach to the application a

proxy, a company resolution or

an equivalent document

granting the representation

powers.

Condition 2

This condition is only available

for those companies who are

willing to apply for an

investment project approval by

the Ministry of Planning and

Development through the

Investment Promotion Centre.

In this specific case, the

limitation of number of allowed

expatriates according to the size

of company is not applicable

and the company will be

allowed to contract the number

of expatriates, according to the

quota authorized by the

Minister of Labour.

Work Permit (above

the quota)

64. According to the labour law, the

Mozambican companies can

still contract expatriates after

having exhausted or exceeded

the allowed quota. In these

cases, a work permit issued by

the Ministry of Labour formally

authorizing the expatriate to

work in Mozambique will have

to be obtained, with the ground

that there is no Mozambican

qualified for the job.

Procedures

65. In order to obtain a work

permit authorization, besides

the above referred documents,

it is necessary to submit the

following additional

documents:

a. Declaration from the

trade union body of the

company or from the area

of activity confirming the

number of employees and

foreign employees. In

order to obtain such

declaration, it is

necessary to submit an

application to the

applicable union body,

attaching the documents

mentioned in a) to d)

above. Please also note

that there are fees owed

to the union body, which

vary from one union body

to another;

b. Bank slip proving the

payment of the

administrative fees of 10

minimum wages of the

company’s sector of

activity).

66. Please note that the labour

authorities may ask for

further documentation if they

deem it necessary.

Temporary work declaration

(Short Term Work Permit)

67. A temporary work declaration is

normally applied by foreign

individuals that remain

employed by the foreign

company and come to

Mozambique to assist the local

company on a temporary basis.

68. Should the employee work in

Mozambique for a period not

exceeding 30 days or 180 days

(for Oil & Gas projects)


continuously or in aggregate, a

communication must be

addressed to the Labour

Department, attaching a copy of

the expatriate's passport.

69. The Labour Authorities may

authorize the extension of the

permanence of the expatriate

within the Mozambican

company/branch for an

additional period of 60 days,

provided there are strong

arguments presented by the

Mozambican company/branch.

Please note that the extension is

not applicable for the Oil & Gas

sector.

Work permit and visa requirements

70. Mozambique has strict visa and

temporary resident permit

requirements.

71. A visa only allows a person to

report at the port of entry, to

request admission, whereas a

“temporary resident permit” is

the permission to reside inside

the borders of a country for a

specific purpose. An

Immigration Officer is only

entitled to issue a visitor permit

at the port of entry.

Work Visa

72. The work visa should be

obtained in a Mozambican

Consulate out of Mozambique

once the work permit is

obtained and the application

shall comprise the following

documentation:

– Certified copy of the

criminal record/policy

clearance

(sworn translated to

Portuguese and note that

you may be requested to

present the original

document);

– Specific application form

duly completed


work permit issued;

– Payment of

administrative fees;

– 2 passport photos ;

– Original Passport;

– Medical Clearance (not a

common requirement);

– Company invitation letter.

Once the said visa is

granted, the foreign

nationals shall be able to

enter the country and apply

for a resident permit.

Resident Permit (DIRE)

Application

73. The application to the

Migration Department is made

through completion of a proper

form, attaching the following

documents:

– Application letter signed by

foreign national;

– Application letter issued in

the company’s letterhead,

stamped and signed by the

company’s representative;

– Full certified copy of

passport and presentation

of the original;

– Criminal record (sworn

translated to Portuguese);

– Original work permit and

presentation of

a certified copy;


company's trading license;


company's tax clearance

certificate;

– Payment of

administrative fees.

74. Please note that the physical

presence of the foreign

individual is required at the

Migration offices upon

submission of the application.

75. The resident permit is valid for

1 (one) year and is renewable

for the same period.

Timeframe

In practice, on the first application

the Mozambican Migration

authorities generally take an

average of 45 days from the date of

submission of the application to

grant the resident permit. During

this period the foreign national

cannot leave the country without

prior authorization of the

Migration authorities.


Business Visa

81. This visa should also be obtained

in a Mozambican Consulate and

the application shall be

submitted with the following

documentation:

– 2 passport photos;

– original passport valid for 6

months;

– Hotel reservation;

– Administrative fees that

depend on the Mozambican

Consulate in which the visa

is being applied.

– Specified application form

duly completed;

– Company invitation letter

Please note that Business visa must be used within 60 days after the date of its concession and allows the holder to stay for a period of 30 days, extendable up to 90 days.

Dependents

Dependents of foreign nationals

holding a permanent (not

temporary) residence permit can

work in Mozambique.

Dependents include single children,

siblings and grandchildren under

21, ascendants where there is

evidence that support is needed and

the spouse of a citizen. Note that

Mozambique does not recognize

same gender

marriages. Please note that this list

is not exhaustive.


Step 4: What to do when you arrive in Mozambique

Registration as a taxpayer

76. A foreign national working in

Mozambique is liable to register

as a taxpayer with the local

office of the Mozambican Tax

Authorities.

77. Application for registration

must be made by completing

the specific form. Upon

registration, the Mozambican

tax authorities will allocate you

a unique tax reference number

(NUIT).

78. Subsequently, a specific form

must be completed and

delivered to the employer,

regarding the specific

information on the employee’s

familiar situation. The

information disclosed in this

form will be the basis to

determine the withholding tax

rate applicable to each

employee.

Important tax compliance dates to remember

79. Individual income tax returns

have to be filed:

– From January to March, of

the following year, if the

taxpayer has only earned

income from the First

Category (employment

income);

– From January to April of

the following year, in all

other cases.


Step 5: What to do at the end of the tax year

Tax returns

80. Individuals should collate all

records necessary to

complete the tax return

including the declaration

from the employer detailing

remuneration and

withholdings for the tax

year. Even if an individual is

not paid in Mozambique it

will still be a requirement for

the foreign employee, to

prepare and submit the

referred declaration.

81. Your PwC tax consultant will

prepare the tax return for

you, if authorised to do so.

In order to prepare the tax

return, the tax questionnaire

should be

completed and returned to

your PwC tax consultant.

Notice of assessment

82. The Mozambican Tax

Authorities should issue an

income tax assessment after

submission of an income tax

return, only when the

income was not

automatically withheld at

source at final tax rates.

83. Objections may be lodged

against the assessment, if

the individual does not agree

with the calculation of the

taxable income, the tax

assessed or the tax rebates

allowed. Each notice of

objection should clearly

state the grounds for the

objection.

Payment of taxes

84. Payment of tax due should

be made normally by no

later than 31 May, with some

exceptions, namely:

– Up to 30 June, when the

return has been

submitted up to April;

and

– Up to 31 August, when

the tax returns have

been submitted after the

due time and when tax is

due.

Penalties

85. Penalties range from MT

3,000.00 (approximately €

43.00) to MT 65,000.00

(approximately € 938.00)

and interest may be charged

on late payments. Prison

sentence may be applied in

case of tax fraud and money

laundering.

Objections and appeals

86. In case the tax assessment is

not in accordance with the

tax return filed, a notice of

objection can be filed with

the tax inspector, within six

weeks of the date of

assessment, a notice of

objection can be filed with

the tax inspector.

Interest

87. A taxpayer is liable to pay or

to receive interest when

payments or refunds of tax

are overdue, or when a tax

return's adjustment by the

tax inspector results in

additional tax

payable/refundable. Interest

is calculated at the statutory

rate. The tax

payable/refundable is settled

after the taxation period has

ended.


Step 6: What to do when you leave Mozambique

Ceasing tax residence

88. At the end of employment the

company must inform the

competent authorities of the

individual’s departure and the

original residence permit and

work permit must be returned.


Appendix A: Rates of tax

Personal income tax rates for 2016

Gross Monthly Salary Range

Value of personal income tax to withhold for the lower limit of the gross salary, based on number of dependents

(- indicates no withholding and no coefficient need be applied)

Applicable coefficient for each additional unit of the lower limit of the gross salary

0 1 2 3 4+

Up to 20,249.99 - - - - - -

20,250 – 20,749.99 Coefficient only

- - - - 0.10

20,750 – 20,999.99 50 Coefficient only

- - - 0.10

21,000.00– 21,249.99 75 25 Coefficient only

- - 0.10

21,250.00 – 21,749.99 100 50 25 Coefficient only

- 0.10

21,750.00 – 22,249.99 150 100 75 50 Coefficient only

0.10

22,250.00 – 32,749.99 200 150 125 100 50 0.15

32,750.00 – 60,749.99 1,775 1,725 1,700 1,675 1,625 0.20

60,750 – 144,749.99 7,375 7,325 7,300 7,275 7,225 0.25

144,750 and above 28,375 28,325 28,300 28,275 28,225 0.32


Appendix B: Double-taxation agreements

Botswana

India

Italy

Macau

Mauritius

Portugal

South Africa

United Arab Emirates

Vietnam

Countries with which Mozambique has double-taxation agreements


Appendix C: Mozambique contacts and offices

Contacts

João Martins

Tel: +258 21 350 400

Email: [email protected]

Malaika Ribeiro

Tel: +258 21 350 400

Email: [email protected]

mailto:[email protected]

mailto:[email protected]

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