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1 Recent and upcoming eventsCountry tax updates Update on double tax treaties with African countries PwC publications of interest this issue1 PwC Africa DeskWelcomeAccessing and keeping up with the diverse tax and regulatory changes on the African continent can be challenging. To meet this need, PwC s Africa Desk in Johannesburg provides a snapshot of the most significant recent tax and regulatory changes in Africa through its quarterly newsletter, trust you will find this publication useful and we look forward to receiving your pricingCongo: New requirements regarding transfer pricing documentationMozambique: Council of Ministers approves the transfer pricing regimeSouth Africa: SARS issues final notice on submission of country-by-country reportZambia: Draft amended Transfer Pricing Regulations issued for comment; new disclosure requirementsAfrica publicationsWorldwide Tax summaries Corporate Taxes 2017/2018 now availableFuture National Oil Company of Africa Recent budgets / Finance Act / Finance Legislation1.

2 Democratic Republic of Congo2. ZambiaUpcoming eventPaying taxes Africa launch: Windhoek, Namibia on 29 November 2017 Staying informedAfriTaxQuarter ended 30 September 2017 Issue 34 Recent and upcoming eventsCountry tax updates Update on double tax treaties with African countries PwC publications of interest this issue2 PwC Africa DeskIn this issueUpdate on double tax treaties with African countries PwC s Publications of InterestRecent eventCountry Tax UpdatesAngolaDemocratic Republic of CongoCongo (Brazzaville)GhanaMozambiqueNigeriaSouth AfricaTanzaniaUgandaZambiaBusiness travellers seminarCameroon South AfricaCameroon United Arab EmiratesEgypt Saudi ArabiaKenya China (The People s Republic of)Nigeria SingaporeZambia SwitzerlandAfrican tax publicationsGlobal tax publicationsAfrican industry publicationBankingEnergy EntertainmentAfrican general interest publicationsPwC Nigeria Transparency ReportUganda s Economic OutlookGlobal general interest publicationsMiddle East Economy WatchThe World in 2050 Global State of Information Security Survey 2018 Recent and upcoming eventsCountry tax updates Update on double tax treaties with African countries PwC publications of interest this issue3 PwC Africa DeskRecent eventsAlan SeccombeJohannesburg+27 (11) 797 4110 OlatunjiJohannesburg+27 (0)

3 11 797 5317 and upcoming eventsBusiness travellers seminarOn 20 September 2017, PwC s Africa Coordination Centre hosted clients and colleagues at a breakfast seminar that highlighted the inherent and often ignored tax and immigration risks created by the activities of short-term business travellers. These risks can arise where business travellers are subject to insufficient internal controls for example, frequently they are not monitored from a presence point of view and move in and out of countries with minimal immigration or tax advice. As a result, organisations often struggle to track them and the potential liabilities they create. During the seminar, insights were given regarding best practice in managing these risks, including how PwC leverages technology to this further enquiries, please contact the following:Recent and upcoming eventsCountry tax updates Update on double tax treaties with African countries PwC publications of interest this issue4 PwC Africa DeskUpcoming eventsLorraine Holland-MuterWindhoek, Namibia+264 61 2841034 and upcoming eventsPaying Taxes 2017 Africa LaunchPaying Taxes 2017 is a unique report published by PwC and the World Bank Group that compares tax regimes in 190 economies worldwide based on 13 years worth of data.

4 Through presentations by key speakers from PwC, the World Bank Group, the Ministry of Finance and the Namibian Inland Revenue Department as well as a panel discussion, we will explore the study results from global and local Taxes provides a measure of how easy it is for a business to pay its taxes, looking not only at the tax cost but also at both the pre-filing compliance processes involved in preparing, filing and paying tax and the post-filing processes such as audits and refunds that can occur after a return has been filed. The study also considers the ever greater role that technology plays in tax compliance and the challenges and opportunities that this brings for taxpayers and tax Africa launch event will be taking place on 29 November in Windhoek, Namibia. For further enquiries, please see below contact: Recent and upcoming eventsCountry tax updates Update on double tax treaties with African countries PwC publications of interest this issue5 PwC Africa DeskCountry Tax UpdatesCountry Tax Updates AngolaAmendment of the Angolan General Tax Code by Law 18/17 of 17 AugustPayment of tax may now be made in a foreign currency if a taxpayer obtains more than 60% of their income in foreign currency in a year of assessment.

5 Such payment occurs upon a request by the taxpayer or following an Angolan initiative from the authorities. This means that taxpayers may now pay their taxes in a currency other than the Carvalho EstevesLisbon+351 213 599 601 Peniche AndradeLuanda+244 227 286 109 and upcoming eventsCountry tax updates Update on double tax treaties with African countries PwC publications of interest this issue6 PwC Africa DeskCountry Tax Updates Democratic Republic of CongoProsper BizitouPointe-Noire+242 05 557 51 98 LebrasPointe-Noire+242 05 557 76 76 must now subscribe to a specific declaration containing simplified transfer pricing simplified documentation does not replace the complete documentation. However, it must include general information on the group of related companies (deployed activity, intangible assets, transfer pricing policy) and specific information about the DRC company (deployed activity, summary of intra-group transactions, transfer pricing method used).

6 Value-added tax (VAT) measuresVAT exemption on insurance servicesLife insurance premiums, health care premiums, reinsurance premiums and premiums for direct insurance abroad, if such insurance has been authorised by the Minister, are exempt from exemption on imports by mining companiesGoods imported by mining companies (excluding petroleum products) are exempt from VAT. However, only the holders of mining rights are eligible (sub-contractors are therefore excluded), and the VAT exemption applies only to imports made before the exploitation fraudWith the objective of combating fraud, VAT on transactions carried out by public companies in which the DRC Government holds a 100% interest will now be withheld by the mining VAT device scheduled for 1 January 2019 Reference is made to a tax electronic device for which taxable persons would have to register.

7 This device is intended to be used to collect VAT data from 2019 duties measuresThe duties and taxes payable on the importation of goods and the exportation of mining commodities have been order to combat fraud, a late payment interest is due in the event of non-payment or late payment of customs duties. The limitation period for action to recover duties has been extended to six years (previously three years), and nine years in the absence of a goods declaration form (previously six years).Other measuresSubscription to treasury bondsShort-term loans to the DRC (in particular by foreign persons) s now encouraged. This has been motivated by a waiver of tax ( movable and profits tax) on income derived from treasury taxesThe Finance Law also provides new measures relating to non-tax revenues, such as in the case of tax disputes, where a third of the amount contested must be paid in order to obtain a suspension of Law 2017 Finance Law 2017 came into force on 27 June 2017 in the Democratic Republic of Congo (DRC).

8 The tax amendments will be applied retrospectively with effect from 1 January 2017. Some of the more significant tax changes are described income tax measuresDeductibility of related-party expensesExpenses for services received in the DRC from a related foreign company must now satisfy the arm's length principle in order to be tax deductible. The services must have been actually performed for the DRC company and there should be economic made to foreign companies (including financial institutions) that have been established in a privileged or non-cooperative country are only allowed as a deduction for income tax if:1. They correspond to real transactions; and2. They are not of an abnormal or excessive countries are described as those in which the foreign company is not taxed or is subject to an income tax of less than 50% of the tax that would have been charged if such foreign company had been established in the countries are those that do not comply with international standards on transparency and the exchange of tax note, in order to apply income tax on profits considered to be indirectly transferred from the DRC, the tax authorities no longer have to prove the existence of a relationship between a DRC company and a foreign company established in a country with a privileged or non-cooperative tax paid to foreign related companyInterest paid to a foreign related company used to be tax deductible under only two conditions, :1.

9 Repayment of principal occurs within five years; and2. The interest rate does not exceed the internationally recognised average interbank market rate during the month in which the principal is second condition has now been simplified by allowing the interest to be tax deductible if the rate so charged does not exceed the annual average effective rate charged by a credit institution of the country where the lender is resident. However, this provision does not apply to mining business tax systemAmendment of the threshold for corporate income tax for small businesses from CDF 200,000,000 to CDF 80,000, institutions-specific measuresDeduction of provision for bad debts recorded by credit institutions for corporate income tax requirement regarding transfer pricing documentationFinance Law 2015 introduced transfer pricing rules to combat illicit transfers of profits, requiring DRC companies to have documentary evidence of transfer prices for transactions with foreign related undertakings (de jure or de facto).

10 This documentation must be made available to the tax administration at its turnover threshold has now been introduced, below which DRC companies will be exempt from this obligation (the threshold is to be determined by a regulation). Additionally, the companies Moise KokoloPointe-Noire+242 05 534 0907 and upcoming eventsCountry tax updates Update on double tax treaties with African countries PwC publications of interest this issue7 PwC Africa DeskCongo (Brazzaville)Normal VAT rate on certain products restoredFollowing Circular Note No. 0024/MFB-CAB of 7 September 2017, the Minister of Finance has restored customs duties and taxes on the importation of certain products. This decision was taken with a view to maintaining the activity of local companies and preserving products concerned are those that previously benefited from a reduced VAT rate of 5% following Circular Note No.