o Smaller influx of external resources via the State Budget and Unique Treasury Account
(10% lower compared to that predicted);
o Severe instability in macroeconomic indicators (economic growth (7%), inflation (single
digit), and exchange rate variation (single digit) and deficit in the current account of the
balance of payments in relation to GDP (single digit), with a 5 percentage point greater
variation in comparison with assumed levels;
o Severe political and social instability leading to diversion of attention of the institutions,
or to allocation of resources for other activities;
o Occurrence of severe emergencies and exogenous shocks, internal and external,
namely within the context of regional integration; and
o Combination of negative events previously identified.
112. There is still a major challenge in the reduction of foreign aid dependence, specifically in
relation to financing of the Mozambican state budget, given that the increase in state
expenditure has exceeded the increase in public income, implying a budget deficit, before
donations of 17%, in 2011, despite the tax collection index having increased.
113. The findings converge on the fact that there is an unexploited potential with regard to
companies, particularly large companies, which are in the extractive industry sector. According
to the Bulletin of Tax Statistics (2012; 57) the contribution of megaprojects to State income, in
2011, was below 4%15.
114. Regarding opportunities of increasing income generated by the growing investments,
particularly in the extractive industry, the following strategic actions are taking place:
An inventory of mineral resources;
A revision of the IRPC code, in order to:
i.
ii.
iii.
Clarify the taxation of capital gains resulting from transactions of representative parts
of social capital or other interests and rights carried out outside of Mozambican
territory, between non-resident entities, involving assets situated in Mozambique;
Expand the range of non-deductible charges for tax purposes, through the
establishment of a limit for the deduction of forms of remuneration of partners of
companies, as well as disallowing the deduction of costs shown in documents emitted
by contributors who have irregularities in their Unique Tax Number (NUIT) or whose
activities have ceased.
Introduction of the concept of special relations based on transfer pricing, which was
only considered for issues of under capitalization.
A reform process is under way, with a view to adopting a new Mining and Petrol Fiscal regime
by mid 2013 having.
15
The contribution of the megaprojects was 5, 47%, in 2008; 3,1%, in 2009; 4,76%, in 2010 and 3,46, in 2011.
49