Presidential Decree 89/25, of 23 April 2025, approved the following agreement signed between Angola and the Democratic Republic of Congo:

“Agreement on the Management, Revenue Sharing and Compliance of Tax Obligations in relation to the Block 14/23 Concession Area located in the Common Interest Zone between Angola and the Democratic Republic of Congo”.

The Common Interest Zone was created in 2008 to allow for the joint exploitation of petroleum resources between Angola and the DRC. The zone was converted into Angolan Block 14/23 in 2023. The Block 14/23 area is located south of Angolan Block 14 and north of Blocks 1, 15 and 31.

The main provisions of the Agreement are as follows:

• The Agreement is binding on the two states (Angola and the DRC) and the companies undertaking activities and business in the Common Interest Zone/Block 14/23;
• The oil companies conducting petroleum operations in the Common Interest Zone/Block 14/23 are subject to the Angolan tax laws, including Law 13/04, of 24 December 2004 (Petroleum Activities Taxation Law);
• The tax revenues obtained from activities in the Common Interest Zone/Block 14/23 are shared 50%/50% between Angola and the DRC. This includes revenues from the following taxes:
  • Petroleum Income Tax
  • Surface Fee
  • Training Contribution
  • Stamp Tax
  • Value Added Tax (VAT)
  • Workers Compensation Tax
  • Property Tax
  • Road Tax
  • Bonus and contributions paid under the Production Sharing Contract
  • Penalties and fines
  • Any other taxes, fees or charges applicable on petroleum activities under Angolan law
• The oil companies comprising the Block 14/23 Contractor Group must make all tax payments into a Joint Account held by Angola and the DRC. The Joint Account funds are transferred on a monthly basis to each state (on a 50%/50% split);
• DRC state-owned oil company Sonahydroc, S.A. (or any other entity carrying out petroleum operations in the Common Interest Zone/Block 14/23 on behalf of the DRC) enjoys the same tax incentives applicable to national oil companies (state-owned or private) in Angola;
• The service providers to the Block 14/23 Contractor Group which are incorporated in the DRC or are majority owned by DRC nationals are exempt from Angolan Training Contribution;
• The DRC has the right to appoint 5 (five) representatives to participate in any audits carried out by the Angolan Tax Authority (AGT) in relation to Common Interest Zone/Block 14/23 activities. The states may retain external professional firms to assist in the audits;
• The Agreement is effective on the same effective date of the Block 14/23 Production Sharing Contract and will last for the duration of the contract.

Presidential Decree 84/25, of 16 April 2025, approved the Regulations on One-Stop Shop Platform for Granting Land Rights in Angola. This is one of the items included in the agenda of the Simplify Project approved by Presidential Decree 161/21, of 21 June 2021. Below is a summary of PD 84/25:

• Platform: The “One-Stop Shop Platform for Granting Land Rights” is a technological platform which aims to streamline the process whereby the state grants rights to land that is in its private domain. Public domain land and community land are excluded from this platform.
  
  
• Entities involved: The One-Stop Shop platform aggregates all public entities and services that are involved in the land granting process.
  
  
• Authority: The following entities are responsible for granting land rights:
  1. The Minister of Territorial Administration – In case of the following land:
     • Rural land between 1.000 and 10.000 hectares;
     • Uban land above 2 hectares;
     • Semi-urban land above 5 hectares.
  2. The Provincial Governor – In case of the following land:
     • Rural land between 100 and 1.000 hectares;
     • Urban land between 1 and 2 hectares;
     • Semi-urban land between 2 and 5 hectares.
  3. The Municipal Administrator – In case of the following land:
     • Rural land under 100 hectares;
     • Urban land under 1 hectare;
     • Semi-urban under 2 hectares.

However, in all cases the application for obtaining land rights must be submitted to the Municipal Administrator.

• Process: After filing the application with the Municipal Administrator, the following steps take place:
  1. The office of the Municipal Administrator makes a preliminary review of the application, collects the application fee and schedules an inspection of the land. Inspection is not necessary in allotted/subdivided areas;
  2. The Municipal Urban Management and Land Registry department forwards the file to the Angolan Geographic and Land Registry Institute (Instituto Geográfico e Cadastral) to confirm that there are no pre-existing rights to the land;
  3. The file is returned to the Municipal Management and Land Registry department which inspects the land, provides an opinion on the application and demarcates the land. Demarcation is not applicable in allotted/subdivided areas;
  4. If the authority to grant the right belongs to the Minister of Territorial Administration or Provincial Governor, the file is forwarded to the competent authority. The application is then processed by the Angolan Geographic and Land Registry Institute (Instituto Geográfico e Cadastral);
  5. The file is forwarded to the Tax Office for tax registration of the land;
  6. The competent authority grants the land right.
     
     
• Refusal: The application must be denied if:
  1. The land is part of the state’s public domain;
  2. The land cannot be used by a private person;
  3. In case of community land;
  4. In case of state’s land reserve;
  5. If a pre-existing right exists.
     
     
• Contract & Title: The land right is granted by way of signing a contract (“Land Rights Concession Contract”) and issuing a land title.
  
  
• Registration: The land right is registered with the Real Estate Registry (Conservatória do Registro Predial) and a registry certificate is issued.
  
  
• Pending applications: Applications pending at entry into force of PD 84/25 must be processed under the new One-Stop Shop platform.