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Mozambique — Orbitax Country Chapters
13.1. GAAR and General Anti-Avoidance Measures

There is no GAAR under domestic law. However, there is a general anti-treaty shopping measure whereby treaty benefits are not granted where transactions are so structured as to allow third country residents to obtain such benefits.

Note further that from 2014 onward, all transfers of shares, interest or other rights involving assets located in Mozambique (so-called indirect transfers of assets) are deemed to be sourced from Mozambique and taxable therein, regardless of the identity or residence of the parties to the transfer, the place where the contract is passed or executed, the percentage or holding duration of the interest held, or to whether or not the transfer is made for a consideration.