Corporate Tax 2020

Last Updated January 15, 2020

Congo Brazzaville

Law and Practice

Authors



Sutter & Pearce-Laways is a law advisory firm created in 1997 (as Sutter & Pearce Congo Ltd), , based in Republic of Congo, that has its head office in Pointe-Noire (economical capital) and a representation office in Brazzaville (the state capital). It is specialised with tax laws, both corporate and personal ones, in particular in connection with the petroleum and para-petroleum sectors. It also advises clients performing activities outside these sectors, such as forestry, industry and services. The professional tax team is mainly composed of three persons. Its major involvements in 2019 included providing a technical report to underline the possible aftermath of the project overhauling the forestry code, and the creation of the handbook of tax procedures, as an essential supplement to the general tax code. Sutter & Pearce-Laways is linked with several major networks of law firms, such as VdA (Vieira de Almeida), based in Lisbon, and Centurion, based in South Africa.

Warning: this contribution is based on the tax system applicable as at 31 December 2019, subject to the changes made by the finance law for 2020.

Businesses generally adopt a corporate form, but considering that oil exploration and production is the biggest activity in Congo, a significant portion of this activity is undertaken by foreign companies that register branches in Congo, which duration is in principle limited to two years, but may be extended by Decree of the Minister of Commerce.

Also, short-term contracts to be executed in Congo (six months renewable once) by a foreign company may be handled under a specific legal vehicle called a Temporary Authorisation to Operate (TAO, or, in French, ATE).

Such entities are taxed on the territoriality principle. As a result, Congolese companies carrying on a trade or business outside Congo are not taxed in Congo on the related profits. Foreign companies are only taxable on their Congolese-source profit.

Foreign companies earning revenues from Congo resulting from services rendered to a resident company, except in the case of a tax treaty, are subject to a 20% withholding tax.

Transparent entities exist but are very rarely used.

The criterion for taxation of a Congolese company is the location of the head office, and for the foreign companies, it is the existence of a permanent establishment located in Congo.

This section does not address the tax regime applicable to specific sectors of activities, such as oil exploration and production, and mining.

Tax rates include the following schemes:

  • 1, companies subject to the common corporate tax rate (based on true profit);
  • 2, companies subject to lump corporate tax (precariously installed companies and oil subcontractors); and
  • 3, companies that are tax transparent (partnerships), the revenue of which is taxed under the hands of the partners.

1, The common corporate income tax rate is 30% for commercial companies subject to such taxation.

The minimum tax payable (called Special Tax on Companies, or, in French, TSS) is payable in advance at 1% of the annual turnover and cannot be less than XAF1 million (or XAF500,000 if the turnover is less than XAF10 million a year). Such TSS is deductible against corporate tax.

This TSS is imposed at the rate of 2% on companies that incur tax losses for two consecutive years. This increased TSS is not deductible against corporate income tax.       

These rates are applicable to Congolese companies and to branches of Congolese companies.

2, Legal entities that are considered as oil subcontractors, being foreign companies and also those incorporated in Congo, together with foreign companies exerting their activity through a Temporary Authorisation to Operate, are taxed under a lump taxation scheme, based on a tax rate of 35%, and a deemed distribution of after-tax profit, as follows.

  • The tax burden amounts to 7.7% of the turnover (after deduction of the mobilisation/demobilisation fees), resulting from the following formula:
    1. turnover – 100%;
    2. deemed profit – 22%;
    3. special corporate tax rate – 35% (instead of 30% for the common tax rate);
    4. effective rate – 7.7% of the turnover (22% x 35%);
    5. after-tax deemed profit – 22% - 7.7% = 14.3%; and
  • on a lump dividend tax rating 15%, based on 70% of the after-tax deemed profit; ie, (14.3 x 70%) x 15% (tax rate) = 1.5015%.

This leading to a total tax burden of 7.7% + 1.5015% = 9.2015% of the turnover.

Even though the taxation is not based on true revenue deriving from the financial statements, the companies and the branches that are liable to such taxations must draft and file such accounting documentation.

3, The taxation of partnerships and other transparent entities is made at the level of the partners (shareholders); indeed, the related revenue will be included in the global personal revenue of the latter in the category “commercial/industrial benefits”. The taxation of such total revenue (which includes the following main categories: salaries, non-commercial benefits, commercial/industrial benefits, real estate revenues, etc) is based on the familial quotient (ie, the number of shares depending on the marital status and the number of dependent children. The tax is striking revenue brackets increasingly, as follows.

Income is taxed under a family coefficient system, which adjusts the amount of income subject to the progressive tax rate table according to the number of family members. Under this system, taxable income is divided by the number of family allowances to which the taxpayer is entitled. The amount calculated corresponds to the income per allowance. Tax is then computed for one allowance and multiplied by the number of family allowances.

The following allowances are available:

  • single, divorced or widowed without child – 1;
  • married without child – 2;
  • single or divorced with one child – 2;
  • married or widowed with one child – 2.5;
  • single or divorced with two children – 2.5; and
  • married or widowed with two children – 3.

And so on, increasing by a 0.5 allowance per additional child up to a maximum of 6.5 allowances.

Tax is levied at progressive rates, up to a maximum rate of 40%. The taxable net income for each allowance is taxed by applying the rate:

  • 1% for the fraction of income not exceeding XAF464,000;
  • 10% for the fraction between XAF464,001 and XAF1,000,000;
  • 25% for the fraction between XAF1,000,001 and XAF3,000,000; and
  • 40% for the fraction above XAF3,000,000.

The authors are of the opinion that when the partners of a partnership or other transparent entity are not resident in Congo, the applicable rate is 20%.

The profit is taxed on an accrual basis for the three categories of income taxes, but the types of deductible expenses are not the same.

Lump Taxation Scheme

The deduction is limited to the following items.

  • The amounts collected as mobilisation and demobilisation of equipment and personnel to the extent that:
    1. these operations result in the transfer of equipment and personnel to the territory of the Republic or outside that territory;
    2. their amounts are reasonable; ie, they do not result in a transfer of remuneration at the expense of that used as the basis for calculating the lump sum margin; in practice, the ratio of 15% (of the total amount invoiced) is currently accepted, provided that this rate may be challenged or a higher rate may be accepted, depending on a case-by-case analysis;
    3. they are billed separately before the arrival, or after the departure, of equipment and personnel from outside the territory of the Republic; and
    4. they are specifically identified on the annual statement given to the Congolese tax authorities by the oil companies.
  • Reimbursements for expenses and ancillary supplies to the extent that:
    1. they are separately billed, resulting in a breakdown between (i) the amount of the expenditure or the price of the supply, and (ii) the cost of care and handling;
    2. they are specifically identified on the annual statement given to the Congolese tax authorities by the oil companies; and
    3. they are declared by service companies.

This type of deductible expense is interpreted in a restrictive way by the tax authorities.

Corporation Tax and the Taxation of Partnership and Transparent Legal Entities

Taxable income is based on financial statements prepared according to the principles of OHADA accounting law.

Business expenses are generally deductible unless specifically excluded by law. The following main types of expenses are not deductible.

  • Any expense paid in cash for an amount exceeding or equal to XAF500,000.
  • Any amount paid to the sole director or sole shareholder of a company.
  • The amount exceeding the one accounted for in terms of fringe benefit for lodging employees, compared to the actual amount of the lease.
  • Head office overhead or remuneration for certain services (studies and technical, financial or administrative assistance) paid to non-residents that exceeds 20% of taxable profit before their deduction (or 2% of the turnover in the case of construction or engineering companies); and, if the shareholder is in charge of management, interest on the portion of the loan exceeding half of the capital stock.
  • Royalties from patents, brands, models or designs paid to a corporation participating in the management of, or owning shares in, the Congolese company.
  • Interest paid to a shareholder in excess of an annual rate determined by the central bank, increased by two points.
  • Interest paid to a majority shareholder or the legal or de facto manager of the enterprise, as soon as the lended amounts exceed half of the share capital.
  • Commissions and brokerage fees exceeding 5% of purchased importations.
  • Certain specific charges, gifts, subsidies and any penalty or fine levied pursuant to laws.
  • Most liberalities (and assimilated payments, such as excessive remuneration paid to a director).
  • Income tax (considered as an allocation of the profit and not as a charge).
  • Provisions – in determining accounting profit, companies must establish certain provisions, such as a provision for a risk of loss or for certain expenses. These provisions are normally deductible for tax purposes if they provide for clearly specified losses or expenses that are probably going to occur and if they appear in the financial statements and on a specific statement in the tax return.
  • Depreciation – land and intangible assets, such as goodwill, are not depreciable for tax purposes. Other fixed assets may be depreciated using the straight-line method at rates specified by tax law. Exceptionally, an accelerated depreciation of 40% for the first year of depreciation may be authorised by the general director of taxes for specific heavy equipments acquired in new state.

There are no special incentives in terms of technology investments under common tax law; however, companies entitled to the ZES regime (see 2.3 Other Special Incentives), whose activity is focused on hi-tech and approved as such, are exempted from corporate tax for ten fiscal years and benefit from a reduced rate of 10% permanently after such period.

Specific regimes provide for advantages in the following cases.

Investment Code

The general regime (so-called G) of the Investment Code provides for the following main advantages, as soon as they realise an investment at least equal to XAF100 million, during the three first years of the exploitation period:

  • exemption of income tax (but the tax administration considers that the minimum tax (TSS) remains applicable; and
  • a 50% reduction of registration duties applicable to corporate operations (increase of share capital, merger, share transfers).

The Investment Code also provides for several additional advantages in the following cases:

  • transformation followed by exportation of more than 20% of the production – exemption of the custom duties applicable to exported goods (except for the 2% computer tax);
  • reinvestment of benefits – reduction of 50% of the income tax for the three-year period following the realisation of the investments; and
  • installation in landlocked areas – an additional tax reduction of 50% of income for the two-year period following the first full tax holiday (under regime G).

Finally, the Investment Code provides for the stabilisation of the tax regime.

Special Economic Zones (in French, ZES)

Congo recently created several ZES, including Free Zones, which are not yet operational; in particular, the conditions to be approved as a ZES investor remain to be determined by implementation provisions.

Companies located therein benefit from the following main advantages.

  • Corporate tax and TSS:
    1. exemption for six fiscal years;
    2. fiscal years seven to ten – rate reduced (from 30) to 5%; TSS from 1% to 0.25%;
    3. further period without limitation – 15% rate (instead of 30%); TSS 0.5% (instead of 1%); and
    4. an accelerated depreciation rate of 40% for the first fiscal year, concerning depreciable assets.
  • Dividend tax:
    1. exemption for six fiscal years;
    2. fiscal years seven to ten – rate reduced (from 15) to 5%; and
    3. further period without limitation – 10% rate (instead of 15%).

Industrial Zones (in French, ZI)

Congo recently passed a law authorising industrial companies meeting several conditions, such as use of more than 50% of local raw materials, exportation-focused units, units bearing economic difficulties being taken over. But this regime is not yet operational.

Companies located therein benefit from the following main advantages.

  • Corporate tax and TSS:
    1. exemption for five fiscal years;
    2. fiscal years six to ten – rate reduced (from 30) to 10%; TSS from 1% to 0.50%;
    3. further period without limitation – 20% rate (instead of 30%); TSS 0.75% (instead of 1%); and
    4. reimbursement of some other taxes (not yet determined).
  • Dividend tax:
    1. exemption for five fiscal years;
    2. fiscal years six to ten – rate reduced (from 15) to 5%; and
    3. further period without limitation – 10% rate (instead of 15%).

The final tax burden derives from a reprocessing of the income (or loss) as shown by the financial statement, by which:

  • some items must be re-integrated in the tax result (such as differed depreciation in the case of a loss, or since the related charges are approved as being tax deductible by tax law); or
  • some items to the opposite must be tax deducted.

This reprocessing leads to a tax result that can be offset against loss reliefs and differed depreciation. 

Losses may be carried forward for three years. Losses attributable to depreciation may be carried forward without limitation. Losses may not be carried back.

Losses may be offset against capital gains.

See 2.1 Calculation for Taxable Profits regarding the deduction of interest paid to shareholders.

With respect to interest paid to banks, there is no limitation on deduction of interest.

A company whose share capital is not held up to 95% at least by another Congolese company that is subject to corporate income tax may constitute itself as solely liable for the corporate tax due as a whole by itself and all the companies in which it holds at least 95% of the share capital, directly or indirectly.

Each one of the group companies must file a tax return in addition to a group tax return filed by this holding company.

This tax return will include neutralisation of double revenues and double deductions.

The option for this tax regime must last at least five years.

To the authors' best knowledge, this consolidation tax grouping has not been implemented yet.

Capital gains are taxed at the regular corporate rate. The tax, however, can be deferred if the proceeds are used to acquire new fixed assets in Congo within three years or in the event of a merger.

If the business is totally or partially transferred or discontinued, only half of the net capital gain is taxed if the event occurs less than five years after the start-up or purchase of the business, and only a third of the gain is taxed if the event occurs five years or more after the business is begun or purchased. The total gain is taxed, however, if the business is not carried on in any form by any person.

Finally, there is a special capital gain rating of 20%, striking the capital gains realised by any person domiciled outside Congo, resulting from the sale of any share held in the share capital of a Congolese company.

Indeed, the Congolese company is jointly liable together with the non-resident seller and purchaser towards the Congo.

Transactions construed as sale of goods or services are subject to indirect taxations.

  • Sales of movable properties are liable to both:
    1. a registration duty of 4% (subject to a specific regime of commercial deeds, but this regime is challenged by the tax administration); and
    2. VAT at the rate of 18.9%.        
  • Sales of real estate properties are subject to a registration duty of 15%, exclusive of VAT:
    1. sales of services are subject to a registration duty of 1% (subject to a specific regime of commercial deeds, but this regime is challenged by the tax administration); and
    2. VAT at the rate of 18.9%.

These taxes are due by the purchaser, but the seller is jointly liable for the payment of the registration duties.

Incorporated businesses are subject to several other notable taxes, such as the following.

  • Value added tax (VAT) – 18.9%.       
  • Business activity tax (patente), calculated on the turnover, by cumulated slices, from 0.750% for a turnover not superior to XAF20,000,000, to 0.045% for a turnover superior to XAF20 billion.
  • Payroll tax (in French, TUS), paid by the employer – 7.5% based on the gross salary.
  • Withholding tax on dividends (cf 4.1 Withholding Taxes).
  • Social security contributions – such contributions are withheld monthly by employers. The tax base includes all compensation, benefits and allowances. The law provides for two cappings, so that the contributions due are the following ones:
    1. retirement – 12% total rate; 8% due from the employer; 4% due from the employee; XAF1,200,000 capping;
    2. familial contribution – 10.035% total rate; 10.035% due from the employer; 0% due from the employee; XAF600,000 capping; and
    3. work accidents – 2.25% total rate; 2.25% due from the employer; 0% due from the employee; XAF600,000 capping.

Most of the local businesses held by Congolese nationals operate in non-corporate form, joint ventures taking the shape of a company are rarely used.

The basic corporate tax rate of 30% is lower than the maximum individual rate (40%), but as soon as you aggregate dividend tax to corporate tax, the total rate exceeds the individual rate of taxation for local tax residents.

Roughly and theoretically, a corporate income will bear a 30% corporate taxation, plus a 40% dividend tax based on the net income ((100 - 30) x 40% = 28); ie, a total taxation burden of 30 + 28 = 58%.

However, if the dividend is distributed to non-residents, the final rate becomes 15% (instead of 40% for residents), and in the case of a tax treaty, Congo taxation gives right to a tax credit in the country of residence of the shareholders.

Accumulated earnings are subject to withholding tax on dividends (15%) three years after having been earned, even if they are not actually distributed. This is a strong incentive for not keeping the reserves in the company, and it also reduces the investment capacity to the extent of the tax paid.

The dividends are taxed at the rate of 15% (subject to tax treaties, which may provide for favourable rates).

The gains on the sale of shares of a Congolese company held by any shareholder that is non-resident in Congo are subject to a taxation of 20%, to be paid at the same time as the registration duties of 5% (this last tax burden bears on the purchaser).

There are no listed companies in Congo, nor publicly traded corporations.

However, the law does not make any distinction based on such criteria.

Interest and dividends paid are subject to a 15% withholding tax, in the absence of an income tax treaty. No relief is available.

Four tax treaties are enforceable with the following countries:

  • since 1966 – Central African Economic and Monetary Community (CEMAC) members; ie, in addition to the Republic of Congo, Chad, Gabon, Cameroon, Equatorial Guinea and the Central African Republic;
  • since 1989 – the Republic of France;
  • since 2015 – the Republic of Italy; and
  • since 2015 – the Republic of Mauritius.

A tax treaty with China has been signed but is not yet enforceable.

Although the authors have not experienced such cases, local tax authorities would challenge the use of treaty country entities by non-treaty country residents.

Although there are accurate provisions in the tax law regarding such issue, the tax administration has not yet issued an instruction of application, leading to a certain incertitude in this respect.

But, clearly, intercompany prices must be determined at arm’s length.

No information has been provided in this jurisdiction.

Local transfer pricing rules do not vary from OECD standards, but there is no experience about enforcement so far (see 4.4 Transfer Pricing Issues).

No response has been provided in this jurisdiction.

From a corporate tax and a dividend tax point of view, there is no difference between local branches and local subsidiaries.

From a VAT point of view, the authors are of the opinion that the services rendered by the head office of a branch to the branch itself are not subject to VAT as the branch is not a legal entity, as long as the charge is made with no mark-up; ie, at cost.

From a withholding tax point of view, the authors are also of the opinion that the services rendered by the head office of a branch to the branch itself are not subject to WHT as the branch is not a legal entity, as long as the charge is made with no mark-up; ie, at cost.

However, the tax administration challenges these positions from time to time. In principle, submitting such charges to VAT should be neutral, but due to the lack of reimbursement of VAT credits by the state, paying VAT upfront often becomes a final charge, which is not deductible in terms of corporate tax.

The gains on the sale of shares of a Congolese company held by any shareholder that is non-resident in Congo are subject to a taxation of 20%, to be paid at the same time as the registration duties of 5% (this last tax burden bears on the purchaser).

Such taxation is validated by most of the tax treaties enforceable in Congo (France/Italy) but not for the Mauritius one, as long as the shareholding concerned exceeds 25%.

This taxation (see 5.3 Capital Gains of Non-residents), according to the wording of the legal provision, should not be extended to transactions that would lead to the indirect transfer of such stock; for instance, by way of the sale of the stock of the holding company (of the local company).

This remark also applies for the tax treaties.

No formula is used to determine the income of foreign-owned local affiliates selling goods or providing services.

Please see 2.1 Calculation for Taxable Profits.

See limitations on deductibility of interest paid to a shareholder in 2.1 Calculation for Taxable Profits.

Pursuant to the principle of territoriality, the income earned by a local corporation deriving from a foreign country is not taxable in Congo, as soon as the activity is carried on by a permanent establishment.

If the income does not derive from such establishment, it is taxable in Congo.

The notion of permanent establishment is not defined by tax law but can be taken from the definitions of such type of establishment in the OECD Model Tax Convention.

Pursuant to the territoriality principle, the charges borne locally for supporting an establishment of the local company located in a foreign country are not deductible from a corporate tax point of view.

Dividends received from foreign subsidiaries located in the CEMAC area are taxable on the basis of 10% of the net amount received. However, the holding company must have a minimum share of 25% in the share capital of the subsidiary, and the holding company must be the owner of this share from the creation of the company; if not, then the holding company must commit to keep the shareholding for a further period of two years.

Finally, this favourable regime does not apply to credit establishments (banks).

If these conditions are not met, the dividends are fully included in the taxable profit of the local company.

The authors have not experienced the scheme based on a use by a non-local subsidiary of an intangible asset (patents, know-how) developed by a local corporation.

Indeed, the general corporate scheme is based on a parent company holding a subsidiary in Congo, and not the opposite.

However, if this scheme did happen, the tax administration would certainly want to tax the service rendered by the local company, and would attempt to assess it through the actual profitability of this intangible.

For such purpose, the tax administration may use the tax principle developed under the francophone tax system, called an abnormal management act, the purpose of which is in particular to reintegrate in the taxable profit of the company a deemed profit. However, in such case, the tax administration must establish the proof of this abnormality.

See 6.3 Taxation on Dividends from Foreign Subsidiaries and 6.4 Use of Intangibles.

The authors have not experienced such taxations of local corporations on the income of their non-local subsidiaries or branches as earned under controlled foreign companies-type rules.

No information has been provided in this jurisdiction.

In the case of a sale of shares of a subsidiary, the authors are of the opinion that the capital gain is taxable according to the favourable rates as stated in 3.4 Sales of Shares by Individuals in Publicly Traded Corporations.

In terms of direct or indirect taxations, the provisions of tax law provide that the tax administration is never committed by the stipulations of a contract or the qualification given to situations, and may always requalify them from a tax point of view.

The tax audit cycle is divided into several phases, ruled by the contradictory principle (ie, according to the rule that both parties shall be heard permanently).

  • Examination of documentation and providing explanation; this phase takes place in the premises of the taxpayer. Except for specific cases, no delay is provided.
  • The tax officials issue a notice of reassessment, raising various problems, grounded by a legal argumentation.
  • The taxpayer responds to the notice, within 30 days from its receipt (the delay may be extended upon justified request).
  • The tax officials must confirm their final positions in the light of the arguments raised by the taxpayer; this confirmation must take place within 60 days from the receipt of the taxpayer's response, otherwise the procedure is cancelled.
  • Upon receipt of this confirmation letter, the taxpayer may enter the contentious phase if he keeps on opposing the tax officials' position.
  • This contentious phase is itself divided into:
    1. the administrative procedure (including providing a statement of case within three months from the notice of recovery sent by the Treasury, along with a request for suspension of forced recovery measures); and
    2. the judiciary procedure, if both parties keep on disagreeing or after six months without a reply from the tax administration.

Although the Republic of Congo is a member of the OECD/G20 Inclusive Framework on BEPS, these issues have not been discussed so far, and it is assumed that none of these changes has been implemented.

See 9.1 Recommended Changes.

As a general remark, international tax does not have a high public profile in this jurisdiction.

Furthermore, the tax treaties that are part of the international tax law of Congo are challenged de facto or de jure.

De facto: often during tax audits, tax auditors obviously avoid considering the specific regime deriving from the tax treaties, or deliberately provide arguments in response for the purpose of ignoring the consequences of such regime.

De jure: the Finance Law for 2019 implemented the non-deductibility of VAT applicable to the completion of services rendered by foreign companies that are non-resident in Congo, when such services did not bear WHT (ie, this concerns companies that have their head office in countries that have signed with Congo a tax treaty whose purpose is to avoid double taxation), thus recreating a double taxation from an economic point of view.

No information has been provided in this jurisdiction.

No information has been provided in this jurisdiction.

The changes recommended by the BEPS process have not been implemented in this jurisdiction.

As mentioned in 1.1 Corporate Structures and Tax Treatment and 1.3 Determining Residence, the taxation of legal entities in Congo is based upon the principle of territoriality, according to which the benefits of an entity are taxable in Congo as far as an establishment is located therein.

However, except in the case of a tax treaty, revenues earned by non-residents are generally subject to a withholding tax rate of 20% of the gross revenue.

This taxation is applicable to interest paid to foreign entities, which is an incentive to use the credit establishments located in Congo.

No information has been provided in this jurisdiction.

No information has been provided in this jurisdiction.

So far, transfer pricing has not been treated as a subject of the utmost importance in itself, but remains a concern to be taken care of on a case-by-case basis.

This is partially due to the economic framework of the Republic of Congo, the main revenues of which are based on derogatory law regimes (in particular for the oil industry, and the para-petroleum sector, but also, to a lower extent as a new sector, for the mining sector).

The contemplated decrease of the relative importance of oil activities versus new or developing sectors (such as mining and agriculture) will certainly put the focus on the transfer pricing rules in the upcoming future.

No information has been provided in this jurisdiction.

So far, in the authors' experience, no changes have been made or discussed in relation to the taxation of transactions effected or profits generated by digital economy businesses operating largely from outside the Republic of Congo.

So far, in the authors' experience, the Republic of Congo has not taken a position in relation to the BEPS proposals for digital taxation, and no proposals have been brought forward in this respect.

So far, the Republic of Congo has not introduced any particular provisions dealing with the taxation of offshore intellectual property that is deployed within the country, other than taxation through a 20% withholding tax, if such activity leads to an invoicing.

There are no other general comments in this jurisdiction.

Sutter & Pearce-Laways

Avenue de Loango, Immeuble PBG
Pointe-Noire
Kouilou Region
Congo Brazzaville

+242 06 655 4343

secretariat@laways.africa www.sutter-pearce.com
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Law and Practice

Authors



Sutter & Pearce-Laways is a law advisory firm created in 1997 (as Sutter & Pearce Congo Ltd), , based in Republic of Congo, that has its head office in Pointe-Noire (economical capital) and a representation office in Brazzaville (the state capital). It is specialised with tax laws, both corporate and personal ones, in particular in connection with the petroleum and para-petroleum sectors. It also advises clients performing activities outside these sectors, such as forestry, industry and services. The professional tax team is mainly composed of three persons. Its major involvements in 2019 included providing a technical report to underline the possible aftermath of the project overhauling the forestry code, and the creation of the handbook of tax procedures, as an essential supplement to the general tax code. Sutter & Pearce-Laways is linked with several major networks of law firms, such as VdA (Vieira de Almeida), based in Lisbon, and Centurion, based in South Africa.

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