imageAngola | Presidential Law Decree No. 5/10, of 1 June 2010

Tax Regime applicable to the Sonaref Project

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Presidential Legislative Decree No. 5/10 of 1 July 2010 Whereas in recent years demand for fuels has grown significantly, and Angola has become an importer of petroleum products. Bearing in mind that recent findings point to an increase in heavy crude oil production, and the incremental volume is projected to contribute to refining capacity. Whereas Sonangol - E.P. (“Empresa Pública”, Public Company) is the promoter of a project for the construction of a high conversion refinery with the capacity to process 200,000 barrels of oil per day of acid and heavy crude oil, called the “Sonaref Project”. Bearing in mind the inexistence of a special tax and customs regime for refining, this is currently taxed in accordance with the rules of the general business taxation regime, which does not have a sufficiently comprehensive tax exemption and benefits scheme that makes the project economically viable. Considering that, pursuant to subparagraph (o) of article 165 of the Constitution of the Republic of Angola, and paragraph 3 of article 11 of Law No. 13/04 of 24 December 2004 (Law on Taxation of Petroleum Activities), the National Assembly and under the terms of articles 1 and 2 of Law No. 8/10 of 30 June 2010, Legislative Authorization Law, the Holder of the Executive Power is hereby authorized to rule on tax and customs matters related to the Sonaref Project. The President of the Republic, in accordance with paragraph 1 of article 125 of the Constitution of the Republic of Angola, decrees the following: THE TAX REGIME AND SPECIAL CUSTOMS IMPLEMENTATION OF THE SONAREF PROJECT