background image
12.4.3. Documentation Requirements

Disclosure Requirements

Taxpayers with operating revenue above AOA 7 billion and classified as large taxpayers (see definition above) are required to prepare, maintain and submit a transfer-pricing file (containing details of transactions, relationships, pricing methods followed, etc.) to the Angolan tax authorities, within six months following the end of the tax year.

Standard Documentation

Taxpayers with operating revenue above AOA 7 billion and classified as large taxpayers (see definition above) are required to prepare and maintain contemporaneous transfer pricing documentation.

  

Country-by-Country Reporting

Angola has to date not introduced a Country-by-Country reporting requirement. However, Angola has joined the OECD’s Inclusive Framework which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.

Language of Documentation

The documentation must be maintained in Portuguese.

Transfer Pricing Penalties

The regulations do not foresee TP—specific penalties and those provided for under general tax law would apply. Where TP adjustments are operated, the tax authorities are empowered to apply penalties ranging from 50% to 200% of the underpaid tax, in addition to late penalties of 2.5% per month.