Angola: Angola and DRC Common Interest Zone

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.