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The Convention to Eliminate Double Taxation between Portugal and Angola

Angola has signed with Portugal its second Convention to Avoid Double Taxation (the first was with the United Arab Emirates) which will come into force from 2020. A long-awaited measure and an important milestone in the relationship between both countries.

The convention, which adopts a broadly-based concept of permanent establishment, aims at eliminating or mitigating double taxation on income, including service rendering, interest, dividends and royalties (copyright, trademarks, etc.).

Under the Convention, with respect to taxation of interest, withholding tax may not exceed 20% of the gross amount, while taxation of royalties may not exceed 8% and dividends will be taxed at the rate of 8% or 15%, depending on cases. As regards to the taxation of fees for the provision of technical services, the Convention provides for the application of a reduced withholding tax which may not exceed 5% of its gross value.