Mozambique – CIT: Main amendments to the Corporate Income Tax Code

In brief

Law No. 12/2025, of 29 December, published in the Official Gazette No. 248, introduced a set of amendments to the Corporate Income Tax (CIT) Code, approved by Law No. 34/2007, of 31 December, as amended.

The following articles were amended: 3, 5, 20, 62, 67 and 75. Articles 39, 47, 75 (2) and 76 of the Code were revoked, and Article 61-A was added.

In detail

Main highlights:

• Permanent Establishment: 
  • Shorter permanent establishment period: reduced to 90 days for construction, installation and assembly projects.
  • Services permanent establishment: Introduction of a rule creating a permanent establishment where services, including consultancy and professional services, are provided for more than 90 days, in aggregate within any 12‑month period, regardless of physical presence.
• Digital Economy Taxation: 
  • For legal purposes, the concept and definition of digital goods and services have been introduced.
  • New rules for the taxation of digital goods and services, including those rendered by non-residents, which are now subject to 10% withholding tax.

• Electronic Currency Commissions: Commissions on electronic currency transactions are now subject to 10% withholding tax.
• Capital Gains:
  • Capital gains are now subject to autonomous taxation at 32%.
  • The reinvestment regime applicable to capital gains arising from the sale of fixed assets has been revoked.
• Taxable event on witholding tax: Inclusion of the moment of cost recognition as one of the triggering events for withholding tax purposes.
• Mandatory computerized accounting: Companies must maintain accounting records in   computerized financial reporting systems.
• Elimination of special regimes: The simplified bookkeeping and income determination regimes have been eliminated. Taxpayers previously registered under these regimes are required to transition to, and be classified under, the organised accounting regime.

This Law entered into force on 1 January 2026.

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