Tax incentives for ExxonMobil-operated Blocks 30, 44 and 45

Following the Parliament authorization given by Laws 3/23, 4/23 and 5/23, dated 21 July 2023, the President of the Republic has enacted the package of tax incentives for Blocks 30, 44 and 45. This was done by way of Presidential Legislative Decree 2/23 (Block 30), 3/23 (Block 44) and 4/23 (Block 45), all dated 8 August 2023.

The tax incentives comprise the following:

• Petroleum Production Tax (Royalty) set at 8%
• Petroleum Income Tax (PIT) set at 25%
• 3-year depreciation (at 33.33% per year) for capex
• Allowance of an Investment Premium to be deducted against PIT

These incentives are subject to the following conditions:

• The distance between the Block and the production facility must be longer than 250km at the time the Risk Service Contract is signed;
• The water depth at which a well is drilled is greater than 2000 meters.

ANPG (the Angolan Petroleum Regulator) is responsible for informing the Ministry of Petroleum (MIREMPET) and the Ministry of Finance that the above conditions have been met.

The above tax incentives will be maintained in the event of any unitization, merger or joint development between Blocks 30, 44 and 45. In the event such unitization or joint development also involves other blocks, the tax regime of each block will apply.

Blocks 30, 44 and 45 are located deep offshore in the Namibe basin. ExxonMobil is the operator in all blocks with a 60% interest, with Sonangol P&P holding the remaining 40%. The tax incentives are intended to improve the economics of the blocks and incentivize work/investment in the largely unexplored Namibe basin.

These blocks were awarded to ExxonMobil and Sonangol P&P in 2019.

Rui Amendoeira – OneLegal Partner