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4.1. Domestic PE of a Foreign Entity

The concept of PE in Angola is largely similar to that outlined by the UN Model Double Taxation Agreement. The following forms of business activity is deemed to constitute a PE in Angola:

  • a place of management;
  • a branch of a foreign enterprise;
  • an office of a foreign enterprise;
  • a building site or a construction project, or supervisory activities connected to such site or project where such site or project or activities continue for a period of more than 90 days in any given 12-month period; and
  • the furnishing of services including consultancy services by the employees or other contracted personnel where such activities continue within Angola for a period of at least 90 days in any given 12-month period.

When a foreign enterprise is deemed to have PE in Angola, income from business activities conducted through the PE in Angola will be subject to tax in country.