Mozambique :: SADC Investment Portal

Mozambique

Country Profile

Mozambique flag Mozambique is situated on the south-eastern coast of Africa. It borders Tanzania to the north, Zambia, Malawi and Zimbabwe to the west, South Africa and Eswatini to the South and Indian Ocean to the East. This location puts the country in a strategic position in the Southern African region with its ports giving easy access to international markets and being the first choice for regional importers and exporters. Mozambique has 11 provinces from North to South: Cabo Delgado, Niassa, Nampula, Tete, Zambezia, Manica, Sofala, Inhambane, Gaza, Maputo Province and Maputo City.

The constitution of the Republic of Mozambique sets clearly its economic and political system: Democratic and Multiparty System and Free Market Economy. The government system is a presidential republic; the chief of state is the president, and the head of government is the Prime Minister. Mozambique has a variety of private freedom combined with centralized economic planning and government regulation.

The country has a varied geography with mostly coastal lowlands, mountains in the south and a long coastline of 2700km.

Economic Overview

Real GDP growth rose from 2.3%in 2021 to 3.83% in 2022 and is projected to rise to 4.8% in 2023 and 8.3% in 2024 pushed by extractives and agriculture leading GDP per capita growth to jump from 2% in 2023 and 5.5% in 2024.

FDI inflows in Mozambique have also been growing in a positive trajectory in the recent past as shown in the table below:

Year	FDI Inflows($Millions)
2017	2293
2018	2703
2019	2212
2020	3035
2021	5102

Source: World Investment Report

General Information

Capital	Maputo
Area	799.390 Km²
Population	34,411,456 (2024) (World meter)
Climate	Subtropical (South to North) 18,3oC – 20,0o C during the dry season (May to September) 26,7oC – 29,4oC during the rainy season (October to April)
Languages	The Official language is Portuguese (World Bank)
Currency	Metical (MZN)
Hour	GMT +2 hours
Religions	Christian, Islam, Hinduism and traditional religions
Legal System	Mozambican based on civil law.
Calls	+258 (Code for International calls)
GDP (2022)	17 884 million current US$
Real GDP Growth rate (%) 2022	3.83 % (UNCTAD)
GDP Per capital (USD)2022	542 (UNCTAD)
Consumer Price Index (CPI) growth 2022	9.77 % (UNCTAD)
Main sectors contributing to GDP (2022)	Services, agriculture, Extractives and manufacturing (World bank)

Why Invest in Mozambique?

a) Business Climate

To make Mozambique competitive in attracting investment, the Government has embarked on macroeconomic reforms, with emphasis on fiscal and monetary policy, the commercial code and legislation with impact on business and investment, which has resulted in the simplification of procedures for investing, reduction of tax burden and the adoption of the best international practices in investment matters.

b) Bilateral Investment Treaties

Mozambique has signed bilateral investment treaties (BIT) with 29 countries. It is also party to nine treaties with investments provisions (TIPs), including the 2006 Southern Africa Development Community (SADC) Protocol and the 2005 Mozambique - U.S. Trade and Investment Facilitation Agreement (TIFA). Mozambique is also a State Party of the AfCFTA (47th member to finalise the ratification process of the AfCFTA agreement on July 2023).

c) Double Taxation Agreements in Force

Mozambique currently has signed Double Taxation Agreements with Portugal, Italy, Mauritius, United Arab Emirates, South Africa, Macau Special Administrative Region of the Republic of China, Botswana, Vietnam and India.

d) Robust Investment Legal Framework

Mozambique has a legal framework that promotes and protects foreign and national direct investment, and allows the export and/or repatriation of capital and dividends linked to the investment made. The Investment Law, law 8/2023 of 9 June 2023 expressly establishes the rules applicable to private investments eligible for certain tax and non-tax guarantees and incentives subject to the conditions provided for in the Tax Benefits Code.

The Mozambique Labour law also guarantees workers equal rights at work, regardless of their ethnic origin, place of birth, language, colour, race, sex, gender, marital status, age, within the limits established by law, social status, religious or political ideas.

The following principles and investment guarantees apply to investors:

The principles of equal treatment and non-discrimination between Mozambican and foreign investors;

Respect for property rights and other real rights;
Free competition and ethics among economic operators;
The protection of investments and the free movement of goods and capital, under the conditions and within the limits established by law;
The right to manage companies and maintain in force the licences and authorisations obtained (without prejudice to the possibility of their revocation, cancellation, annulment or declaration of nullity, following the administrative or judicial procedure provided for by law);
The right to import goods from abroad for the execution of the projects and to export goods, whether produced by them or not, without prejudice to the rules of protection of the internal market established by law;
Transfer of exportable profits abroad; from royalties or other investment remuneration income; capital amortization of interest on loans contracted abroad and applied in the project; of foreign capital invested and re-exportable; proceeds from compensation received as a result of expropriation, nationalization or any other equivalent measures.

e) Infrastructure

Mozambique provides rail and road connection to the sea through its ports to 5 countries in the region, including South Africa. The main ports of Maputo, Beira and Nacala are at their peak of performance following upgrading.

Roads and bridges are being upgraded everywhere in the country and new ones are being built. Thanks to these developments, it is now effectively possible to move freight from the south to the north and between provinces. Drive from South Africa to Mozambique is a matter of hours due to the Maputo-Katembe Suspension Bridge and tar road which connects Maputo to Nata. The new tarred road running down from Maputo to Kosi Bay border and linking with Ponta do Ouro is also complete.

Mozambique Airports are distinguished into international airports, main and secondary aerodromes.

International (Maputo, Beira and Nacala);
Regional entry points (Nampula, Pemba, Tete, Vilankulo and FJN);
entry points (domestic) (Quelimane, Lichinga, Inhambane, Chimoio and M. Praia); and
Secondary aerodromes (Lumbo, Angoche, Songo, Ulongue, Bilene, Inhaca and Ponta de Ouro).

The International and Regional Airports establish connections with the world.

f) Abundant Natural Resources

Mozambique has rich and extensive natural resources that have remained largely unexploited. The country’s principal natural resources are natural gas, coal, mineral, sand, hydropower. The key metallic resources are iron ore and tantalite, gold, graphite, bentonite, and limestone are also mined and quarried.

Agency for Promotion of Investments and Exports (APIEX)

APIEX is the primary point of contact for investors in Mozambique. It operates under the Ministry of Industry and Commerce (MIC), with the objective of facilitating private and public investment. It also oversees the promotion of national exports and assists investors with administrative, financial, and property issues. Through APIEX, investors can receive exemptions from some customs and value-added tax (VAT) duties when importing “Class K” equipment, which includes capital investments.

APIEX acts as a One stop shop for investors through provision of the following services

Company registration;
Business licensing;
Work and residence permits;
Concession of land for investment purposes;
Request for tax incentives;
Registration of foreign capital.

Mozambique has also established other One stop shops which are concentrated units for the provision of public services, where citizens, in general, benefit from various services, obtaining answers to their concerns, within the established deadlines.

Streamlining administrative procedures through the establishment of One-Stop-Shops has greatly reduced time, transaction costs and duplication for both citizens and government.

Investment Incentives

Corporate - Tax Credits and Incentives

They include:

a) Foreign Tax Credit

Resident companies are allowed to deduct a credit correspondent to a tax paid abroad. The tax credit to be deducted should be equal to the lower of the amount of Mozambican CIT imputed to income obtained abroad or the amount of foreign tax effectively paid.

b) Credit for Domestic Economic Double Taxation

When the taxpayer is not eligible for the participation exemption mechanism, they are required to include the profits distributed by resident entities in their taxable profits. In such cases and in order to mitigate the impact of economic double taxation, those taxpayers benefit from a tax credit to be deducted from the tax assessed, which corresponds to 60% of the CIT of the distributed profits that are included in the taxable profits.

c) General Tax Benefits and Incentives

In addition to the guarantees of ownership and remittance of funds abroad, the Mozambican government also guarantees the concession of tax and customs incentives. The incentives vary depending on whether a company is starting a new venture or rehabilitating one and also on the nature of the project to be developed. The incentives discussed in this section are the generic benefits applicable to standard projects. Certain specific benefits also may be applicable depending on the activities of the industry for the investment project (e.g., agriculture, mining).

Income Taxes

a) Accelerated Depreciation

Accelerated depreciation of new buildings used in the pursuit of the investment project, as well as rehabilitated buildings, machinery, and equipment intended for industrial or agro-industrial activities, by increasing the normal depreciation rates by 50%.

b) Tax Deductible Expenditures

The amount corresponding to 110% or 120% of the actual cost (depending on the location of the project) incurred with infrastructure considered to be of public utility for a period of five years.

The amount corresponding to 50% of the actual cost costs incurred with the acquisition of Mozambican art or cultural work for a period of five years.

c) Deductions to Taxable Income

Deductions to the taxable income of the amounts invested in (i) professional training of Mozambican employees and (ii) the modernisation and introduction of new technologies, up to a limit of 5% and 10%, respectively, during the first five years.

d) Investment Tax Credit

A carry-forwardable investment tax credit of 5% to 10% of the total investment realised on assets directly associated with the production activity of the operating company (depending on which location the project is implemented in), for a period of five years, to be offset against the gross income tax, up to its total amount.

e) Taxes and Duties on Import of Goods

An exemption from customs duties and VAT applies upon the importation of capital equipment listed in Section K of the Customs Tariff Schedule.

Sector-Specific Tax Benefits and Incentives

a) Processing Industry

Exemption from payment of customs duties on imports of materials for the industrial production process.

b) Agriculture and Fisheries

10% reduction in the CIT rate until 2025 (Corporate Income Tax Code through Law 20/2022);
Withholding tax rate at 10% on payments to foreign entities providing services to national agricultural companies (Corporate Income Tax Code through Law 20/2022);
Elimination of the withholding tax on interest from external financing for agricultural projects; and creation, within the next three years, of tax incentives for new investments in the agriculture, agro-processing, manufacturing, tourism and urban transport sectors through accelerated depreciation (for half of the useful life) for investments made in facilities and equipment related to the company’s production activity, provided it creates at least 20 permanent jobs(Corporate Income Tax Code through Law 20/2022).

c) Upstream Petroleum and Mining

Reduction of withholding tax rate from 20% to 10% for income derived by non-residents for tax purposes in connection with services related to upstream petroleum and mining activities;
Exemption of customs duties on the import of equipment or exploration operations, classified under class K of the Customs Tariff Schedule, as well as on import of pre-determined goods intended for upstream petroleum and mining activities, equivalent to goods of class K of the Customs Tariff Schedule, provided such equipment/goods are not produced in Mozambique or, if produced, do not meet the specific characteristics of the required purpose or are not inherent to the nature of the activity to be developed.

d) Gambling

The gambling concession holders and their shareholders are exempt from CIT. The casino concession holders are also exempt of payment of customs duties, excise duties, and VAT on imports of equipment and materials for the implementation, rehabilitation, expansion, or modernisation and business start-up.

Project-Specific Tax Benefits and Incentives

a) Investment in Science and Technology Parks

The following benefits and incentives apply to investments in scientific investigation, development of information and communication technologies, and Research & Development:

Exemption of CIT in the first five fiscal years.
Discounted CIT rate of:
- 50% from the sixth to the tenth fiscal year;
- 25% from the 11th to the 15th fiscal year.
Exemption of customs duties and VAT on the import of scientific, academic, and laboratory material and equipment, including software and the means that support it, destined for education and technical-scientific research, as well as on construction materials, machinery, equipment, accessories, and spare parts.

b) Investment in Creation of Basic Infrastructure

The following benefits and incentives apply to investments that have as their exclusive purpose the establishment of basic public infrastructure that is essential for the promotion and attraction of investments, for the conduct of specific activities in sectors of the national economy, such as the construction and rehabilitation of roads, rail lines, airports, water supply, electricity, telecoms, and others:

Discounted CIT rate of:

- 80% in the first five fiscal years;
- 60% from the sixth to the tenth fiscal year;
- 25% from the 11th to the 15th fiscal year.

Exemption from payment of customs duties and VAT on the importation of equipment classified in class K of the Customs Tariff Schedule.

c) Large Scale Projects

The following benefits and incentives apply to investments that exceeds MZN 12.5 billion:

Generic income tax incentives;
Exemption of customs duties and VAT on the import of construction materials, machinery, equipment, accessories, spare parts, and other goods destined for the pursuit of the activity.

Specific Tax Benefits and Incentives Based on Special Geographical Areas

a) Investment Carried Out in Special Economic Zones (SEZ)

The package includes:

Exemption of CIT for the first three or five fiscal years, depending on whether it is an SEZ company or the SEZ operator, respectively.

Discounted CIT rate of:

- - 50% from the fourth to the tenth fiscal year or from the sixth to the tenth fiscal year, depending on whether it is an SEZ company or the SEZ operator, respectively;
  - 25% from the 11th to the 15th fiscal year or for the life of the business, depending on whether it is an SEZ company or the SEZ operator, respectively.

Exemption from payment of customs duties and VAT on the importation of materials and goods.

b) Investment Carried Out in Industrial Free Zones (IFZ)

The package includes:

Exemption of CIT for the first ten fiscal years;

Discounted CIT rate of:

50% from the 11th to the 15th fiscal year;

25% for the life of the business.

Exemption from payment of customs duties and VAT on the importation of materials and goods.

Investment Opportunities

a) Agriculture

Mozambique has tropical to sub-tropical climate with fertile soil, ample rainfall, 36 million hectares of arable land, mostly unutilized and irrigatable area estimated at about 3.0 million hectares, eight river basins considered the most favourable for the development of irrigation, Maputo, Limpopo, Búzi, Zambezi, Licungo, Melúli, Lúrio and Rovuma.

Opportunities abound in:

Assembling of agricultural equipment (tractors, farm trucks, harvesting equipment);

Crop growing and value addition in the following select products; maize, rice, potatoes, beans, cassava, poultry, meat, sweet potatoes, vegetables, banana, sugar, sesame, soy, cotton, cashew-nut, macadamia and paprika.

b) Construction

Mozambique faces lack of adequate infrastructures, especially roads, bridges, railways, etc., which are vital for the movement of people and goods. The Government offers multiple investment opportunities for the construction and operation of roads, railway, and general infrastructure by the private sector, under concession or public -private partnership models.

Some of the opportunities include:

Construction of a dock 11 and Fertilizer Terminal in the Port of Beira – Sofala;

Construction of the Nyamayabwe Mutuali Railway Line (Tete, Zambezia and Nampula);

Rehabilitation and Increase of Ressano Garcia Railway capacity, from 20 to 40MTPA;

Rehabilitation and expansion of infrastructure; Increase of cargo transport capacity and mobility to and from South Africa;

Construction of Angoche Port;

BRT Project in the City of Maputo;

Revitalization of Maritime Cabotage in Mozambique;

Construction of the Railway Line Mapai -Massangena Dondo (509.05 km of extension);

Construction of the UTI - Maniamba Railway Line;

Construction of the Ribaue Railway Line - Mocimboa da Praia;

Construction of the Boane- Techobanine railway and its deepwater port at Techobanine (Matutuine district)

c) Energy

Mozambique is endowed with an enormous and diversified energy resource base, most of which remains untapped. Opportunities abound in:

Exploitation of the 23 billion tons of coal reserve potential;

Exploitation of more than 23TW of renewable energy potential;

Nacala Thermal Power Plant (Gas);

100 MW Alto Malema Hydro Power Plant, 60 MW;

Zambezia 300;

Mugeba Hydro Power Plant, 150MW;

Ruo Hydro Power Plant, 85 MW;

Lugenda Hydro Power Plant (Chizeze, Jocozuire, Monte Nandonda), 150 MW);

Tsate Hydro power Plant, 50 MW;

Lurio II Hydro Power Plant, 12 MW;

Massingir 18 MW and/or Mapa Hydro Power Plant, 75 MW.

d) Aquaculture

Mozambique aims to promote the development of aquaculture, with a view to exploiting the existing national potential in a sustainable manner, contributing to food and nutrition security, job creation, contribution to the trade balance and reducing pressure on fishing activity. The government targets to support the small and medium-sized companies to grow, thus transforming subsistence aquaculture into commercial aquaculture. Opportunities exist in:

Fishing of prawns, Tuna, Lobster;

Canning;

Production of fish feed;

Cage culture;

Integrated fish farming;

Cold chains.

e) Information and Communications Technologies (ICT)

Mozambique is yet to realise its full potential in the ICT sector in developing its economy. Opportunities exist in:

Wireless technologies;

Cyber security;

Automation and digitization;

Data centers.

f) Mining

Mozambique's mineral resource potential is large and diverse. There has been an increase in the number of natural resources discoveries that are quickly followed by new mining projects. Besides the coal deposits that emerged in mining projects that have been prominent for some years now, other valuable mineral deposits lying under the Cabo Delgado, Nampula, Gaza and Tete provinces may potentially reward investors and contribute to the country’s economic development. Opportunities abide in: Exploration, Extraction Processing and utilization of various types of resources including:

Gold;

Titanium;

Ilmenite;

Zircon;

Rutile;

Tantalite;

Marbles;

Oil and gas;

Precious stones.

g) Tourism

The tourism assets of Mozambique include the country's natural environment, wildlife, beaches and cultural heritage. Opportunities exist in:

Hotels, resorts, sports and leisure parks;

Historical and cultural sites;

Beach hotels;

Conference centers;

National parks and reserves.

Starting a Business

Forms of business

a) Private Limited Company (Sociedades por Quotas (“SQ”)

Investment Capital Requirements

No minimum capital requirements. However, there must be a minimum of two shareholders, up to a maximum of thirty. There is however an exception in the single person quota company (Sociedade Unipessoal por Quotas) which may be set up by a single quota holder who must be a private individual;

The share capital is divided into participations called “quotas”, whose par value is expressed in local currency. Quotas are always nominative but cannot be lower than MZN 500;

Transfers of quotas inter vivos requires the drafting of a written document signed by the parties and must be communicated in writing to the company and registered at the Commercial Registry Office (Conservatória do Registo das Entidades Legais). Quota holder liability is limited to the value to which each of them has subscribed.

Management

The company is managed by a minimum of one or more directors. The management structure of the quota company comprises the general meeting (deliberative body) and board of directors (management body). Supervisory boards are optional.

b) Public Limited Company (Sociedade Anónima (“SA”))

Investment Capital Requirements

There are no minimum capital requirements, however the entire share capital must be fully subscribed and 25% of the capital must be paid up at the time of incorporation. SAs must be incorporated with a minimum of three shareholders, who may be natural or corporate persons, nationals or foreigners. Where the State is a shareholder whether directly or indirectly, the SA may be formed with the State as the sole shareholder.

Share capital is represented by nominative or bearer shares and the nominative shares may be book-entry or registered. There are few restrictions on transfers, with transfers effected through the simple delivery of the certificates to the transferee; in the case of registered nominative shares, the transfer takes effect by means of a declaration of assignment in the nominative share register book or in any instrument that may replace it; in the case of nominative dematerialised shares, the transfer takes place by the depositary bank recording the transaction in its books or records to the debit of the transferor’s share account and to the credit of the transferee’s share account.

Management

The governance structure of the SA includes the general meeting (deliberative), board of directors (management body) and supervisory board or statutory auditor (supervisory body).

If the share capital of the company does not exceed MZN 500 000, the company may appoint a sole director. Supervision is done by an audit committee with 3 or 5 members or by a sole auditor that must be a registered auditor or audit company.

c) Capital and Industry Company

Investment Capital Requirements

No minimum capital requirements;

There are two types of shareholders for such companies;

Shareholders who contribute to the constitution of the share capital with cash, credits or other material goods and limit their liability to the value of the contribution that they paid up (capitalist shareholders); and shareholders who do not contribute to the share capital. However, they participate in the management and operation of the company but are exempt from any liability for the company’s debts (industry shareholders).

Management

Industry shareholders may have a seat on the management only if they post a bond, which is stipulated in advance in the articles of association, and the amount of which equals the amount of the share capital subscribed by the capitalist shareholders, unless otherwise provided by the articles of association.

d) Single Quota Company

This is set up by a single quota holder who must be a private individual. The share capital is held entirely by the individual.

Company Registration Procedure

1. Name reservation

Name reservations are made at the Legal Entities Registry (CREL) or at One Stop Shops. The name of the company must be chosen in advance and checked at the Legal Entities Registry (CREL to determine whether the name in question or a very similar one does not exist. The name will always be followed by an indication of the legal form of the company. For example, In the case of limited the abbreviation used is “Lda”.

2. Drafting of statutes

With the help of an advisor, an Article of association will be drawn up where the object of the company will be established (the line of business that the company intends to pursue).

The Articles will contain the names of the partners or the partner, with the respective share capital, initial investment money for the company to start up, distributed in shares if there are more than one partner or single share if it is only one partner; the company's address and the various intentions of future partners towards the company. These articles must be signed by the partners and the respective signatures must be recognized in person by the notary, unless a more solemn form is required.

3. Depositing share capital in a bank account

One of the phases of company registration in Mozambique is the opening of a bank account for the purpose of depositing the share capital. For this, it is necessary to present a certified copy of the certificate of reservation of the company name, the draft of the company statutes and a certified copy of the identification documents of the shareholders. When opening a bank account in one of the existing financial institutions in the market in the name of the future company, it is important to define the number of authorized signatures that can oblige the company to handle checks and transfers.

4. Company registration and publication

After the drafting of statutes is done and share capital deposited, these documents must be submitted to the CREL for registration, accompanied by certified copies of the identifications of the partners or the partner. After this submission, definitive commercial certificates will be issued upon payment of a fee which is calculated as a percentage of the share capital. The company is then incorporated and definitively registered for commercial purposes.

After the issuance of the definitive certificate, the statutes must be published in BR so that the company's existence becomes public domain.

5. Tax registration and obtaining the nuit

Once the company is legally registered and the publication of the statutes in the Official Gazette, made by the Conservatory, the company must have a tax register and obtain the respective Tax Identification Number (NUIT).

7. Issue of permit

The request for the issuance of a license is addressed to the Provincial Governor and submitted to the relevant Provincial Directorate of Industry and Commerce. The application must contain the Company name, Address of the registered office, Type of commercial activity to be carried out in accordance with the Classification of Economic Activities (CAE).

For specific cases, especially for companies with commercial points such as stores, bakeries, grocery stores and restaurants, licenses must be requested from the municipal council; Obtaining the license is made upon payment of a fee that varies according to the lines of business.

Company Registration Fees

For acts carried out in the commercial registry services, emoluments and fees are charged, except in cases where the law expressly exempts them from payment.

Clearance Certificate: 76.00 MZM.

For notarial acts and registration of companies up to the value of 5 million MZN, a fee of two per thousand will be charged for each registration The excess amount will be subject to a rate of 0.1 per thousand.

For notarial acts and corporate registration above the value of 5 million MZN, 0.1 per thousand.

Duration

Clearance Certificate: 2 to 3 days;

Obtaining the notarial deed certificate: 4 to 5 days;

Publication in the Boletim da República: up to 90 days;

Final registration: 7 days.

Texation

a) Individual - Taxes on Personal Income

Residents are taxed on their worldwide income. Non-residents are taxed on income arising in Mozambique.

All individual income (employment income, capital gains, investment income, independent work, rental income, commissions, etc.) is subject to the below tax rates.

Annual tax rates applicable to individual income:

Annual income (MZN*)		Rate (%)	Deduction (MZN)**
		Rate (%)	Deduction (MZN)**
Over	Not Over
0	42,000	10
42,000	168,000	15	2,100
168,000	504,000	20	10,500
504,000	1,512,000	25	37,500
1,512,000		32	141,540

* Mozambican metical

** Amount deductible after applying rate to whole amount.

For non-Mozambican residents, the earned income tax is withheld and remitted by the employer or other payer at a definitive flat rate of 20% (in the majority of the income received).

b) Corporate - Taxes on Corporate Income

Resident entities are subject to corporate income tax (CIT) based on their worldwide income.

Non-resident entities with a permanent establishment (PE) in Mozambique are subject to CIT on the income attributable to the PE in the Mozambican territory (i.e., income directly allocated to the PE, as well as any other income sourced in Mozambique derived from activities that are of the same or similar kind as those performed through the PE).

Resident entities and non-resident entities with a PE in Mozambique are subject to CIT that is levied on taxable profits, defined as accounting profits adjusted to comply with tax law rules, at a tax rate of 32%.

c) Value-Added Tax (VAT)

VAT is an indirect tax that is largely directed at the domestic consumption of goods and services and at goods imported into Mozambique. The standard rate is 16%. However, there are certain selected supplies that are subject to a reduced rate of 5% and a few cases where VAT is not due on the full taxable amount, leading to lower effective rates.

All taxpayers with a turnover or goods import operations higher than 2.5 million Mozambican metical (MZN) fall within the standard VAT regime.

Zero-rated supplies (complete exemptions)

The VAT Act contains a list of the supplies of goods or services that are regarded as zero-rated supplies. Most of the items refer to exports and international transport, but other specified goods and services utilised for farming purposes, certain basic foodstuffs, mosquito nets, common bicycles and iron bicycles up to 4 speeds, condoms, and insecticides, among others, are also regarded as zero-rated supplies.

Exempt supplies

Exempt supplies include, among others, banking and financial operation subject to stamp duty, insurance and reinsurance operations subject to stamp duty, residential rentals, medical and sanitary services, and educational services.

Reduced rate supplies

A reduced rate of 5% was recently introduced on the transmission of the following goods and services:

Provision of medical and health services (and closely linked services) by private hospitals, clinics, dispensaries etc.;

Educational services provided by private establishments integrated in the National Education System and recognised by the Ministry of Education, including the supply of related goods and services;

Vocational coaching/training services, along with the supply of related goods and services (e.g., accommodation, food, and teaching material), when carried out by private entities;

Provision of services consisting in private lessons taught on school or higher education subjects.

Note: Expenses subject to a reduced rate of 5% are excluded from the right to deduct the input VAT incurred.

d) Withholding Taxes

Any non-resident entity carrying out economic activities in Mozambique, without being registered as a taxpayer, is liable, in general, to a final and definitive 20% WHT that is applied on all income earned. An exception exists for :

Telecommunications and international transport, as well as the respective installation and assembly of equipment made by the same entities;

Construction and rehabilitation of production, transport, and distribution of electricity infrastructures in the rural zones under the public projects of rural electrification; and

Maritime vessels freight for fishing and coasting activities, all of which are subject to a 10% WHT rate.

In addition, per the recent amendments to the CIT Code, a temporary reduction of the WHT rate to 10% was introduced for income earned by non-residents, deriving from the provision of services to local agricultural companies, until the end of 2025. Further, a temporary WHT exemption was introduced on interest income earned by non-residents in connection with external loans destined to finance agricultural projects, until the end of 2025.

Note

Not all gains sourced from Mozambique by non-resident corporate entities are subject to taxation through WHT. This is the case, for example, of:

Capital gains derived from immovable property located on Mozambican territory or from the disposal of shares in entities with head office or effective management in the Mozambican territory or other movable assets issued by non-resident entities, and

Capital gains derived from the disposal of shares, participating interests, or rights in general between non-resident entities involving, direct or indirectly, assets located in Mozambique.

In such cases, the non-resident entity is required to register itself as a non-resident taxpayer, appoint a tax representative in Mozambique, and subject the gain to 32% CIT. On disposal of immovable property (other than petroleum and mining assets), only 50% of the gain is taxable.

Immigration Procedures

The National Migration Service (SENAMI) is a public service that oversees the area of Migration, (article 2 of Law no. 4/2014, of 5 February).

Visa

All nationalities need a visa to enter Mozambique, except holders of the following passports:

Brazilian and Portuguese diplomatic, service and official passports;

Passports from countries with which Mozambique has a visa suppression agreement; See link for visa waived countries: https://evisa.gov.mz/waiver. Additionally, decree no.10/2023 of 31 March exempts nationals of certain countries from presenting an entry visa. See link for waived countries: https://www.ca.co.mz/xms/files/FLASH_NEWS/Flash_informativo_ENG_Visto_de_entrada_120423_CA.pdf

Visa application process is done online through https://evisa.gov.mz/registerAccount where applicants are able to apply, pay and obtain online.

Types of visas

a) Business Visa - Multiple Entries (valid for 90 days)

This visa is issued to foreigners who are entering Mozambique for the purpose of doing business, research, attending a meeting or to participate in insightful conferences.

b) Investment Visa

This is a visa for foreigners entering Mozambique for the purpose of investing in a project totalling a value equal or greater than US$500 thousand.

c) Tourism Visa

This visa is issued to foreigners entering Mozambique for the purpose of tourism, holiday or vacation.

d) Work Visa

The work visa is granted to foreign citizens who travel to the country with the aim of providing, or temporarily carrying out, a professional activity as an employee, with or without remuneration.

Work permits

Foreign nationals wishing to work in Mozambique are required to obtain a work permit.

There are two Mozambique Work Permits:

Short-Term Work Permit;

Long-Term Work Permit.

a) Short Term Work permit

Short-term work authorizations are designed for foreign workers undertaking work for shorter periods of time. Short term work authorizations can be issued for a period of less than 90 days, or 180 day depending on the sector the local registered entity falls under. A short-term work permit is accompanied by a business visa for entry/exit into Mozambique during the validity of the short-term work authorization. Business visas allow the traveller to stay in Mozambique for a continuous 30 days.

b) Long Term Work permits

These are initially valid for a period of 2 years. They are renewable if the applicant meets the set-up criteria.

Residence Permit

Precarious Residence Permits are granted to foreign nationals who intend to remain in Mozambique for more than 90 days. This authorisation is renewable annually.  

Temporary residence permits are valid for a maximum period of one year and renewable for one-year periods. They are granted to foreigners who have had precarious residence for at least five years and to foreigners who enter the country for residence purposes.