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Mozambique

  • operations subject to Property Transfer Tax (SISA);

  • exploration and practice of certain games of luck and social entertainment;

  • goods allocated exclusively to an exempt sector of activity or that do not entitle one to a right of deduction;

  • goods and services pertaining to agricultural, forestry, cattle and fishing activities;

  • certain equipment, seeds, procreators, fertilisers and fungicides, as well as fishing nets, hooks and other tools for fishing;

  • alimentary oil and soaps;

  • sugar; and

  • acquisition of raw material, intermediary products, spares, equipment and components made by the national sugar industry.

Complete exemptions (zero-rated supplies)

The following transactions are fully exempted:

  • exports (such as transactions and international transport);

  • maize flour, rice, bread, iodated salt, powdered milk for infants up to one year, wheat, wheat flour, fresh or refrigerated tomatoes, frozen horse- mackerel (‘carapau’), illuminating paraffin, ‘jet-fuel’, mosquito nets, common bicycles and condoms;

  • some products resulting from the industrial activity of production of rations for feeding of animals for human consumption;

  • transmission of goods to be used as raw material in the alimentary oil and soap industry, resulting from the industrial activity of production of alimentary oil and soap, carried out by the relevant factory; and

  • transmission of goods and supply of services related to the agricultural activity of production of sugarcane and destined for the industry.

Input tax

Input tax allowed

VAT is fully recoverable, subject to complying with the legal requirements, in the case of taxpayers carrying out fully taxable activities. Taxpayers carrying out VAT exempt activities are not entitled to claim any input credit.

Input tax expressly denied

Input tax is expressly denied in the following circumstances:

  • passenger or passenger/ goods vehicles, pleasure boats, helicopters, aircrafts and motorcycles;

  • fuel used for cars, except for diesel fuel, where 50% of the tax is deductible. However, diesel is fully deductible if related to tractors used for agricultural purposes, certain machines, and large vehicles licensed for the transportation of people or goods, excluding those used in the rent-a-car sector;

  • expenses with business trips and transport for the entrepreneurs or employees;

  • lodging, food and drink, tobacco and entertainment expenditure;

  • telephone communication costs, except those related to fixed telephones in the name of the company; and

  • diversion and luxury expenses.

Partial exemption

Taxpayers simultaneously carrying out taxable and exempt activities can recover VAT on inputs on an apportionment basis.

Adjustments

Application of goods that are part of a business for private use or for non- business purposes when VAT has been deducted on such goods is considered a supply of services. Therefore the taxpayer must pay VAT to the tax authority.

Preregistration and post- deregistration VAT

There are no specific rules regarding the recovery of VAT prior to registration or after deregistration. Companies intending to recover preregistration or post-deregistration VAT should submit an application to the competent Tax Authorities requesting their legal opinion on such procedure.

Imports

Goods

VAT is payable by any importer on the importation of goods. However, importation of the following goods is exempt from VAT:

  • goods that are exempt when sold within the country;

  • certain goods that are duty exempt or declared to suspension procedures;

  • importation of gold by the Bank of Mozambique;

  • re-importation of goods by the entity that exported the goods, when they are exempt from import duties;

  • ships and aircraft used in the international trade and goods for provisioning and fuelling thereof;

  • importation of art objects by the respective artists, authors, heirs or legatees;

  • certain other exemptions and reductions recognised by the Minister of Finance; and

PricewaterhouseCoopers 105

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