Cabo Verde Cross-Border Tax Guide 2026

Overview — Cross-Border Taxation in Cabo Verde

Cabo Verde's cross-border tax rules are governed by the Código de Imposto sobre o Rendimento (CIR) and the Código Civil. The Direção Nacional de Receitas do Estado (DNRE) has been strengthening its international tax capacity, including participation in international tax cooperation initiatives. Multinational enterprises operating in Cabo Verde must comply with transfer pricing documentation requirements and withholding tax obligations. As a member of the Community of Portuguese Language Countries (CPLP), Cabo Verde has preferential tax arrangements with other Lusophone nations. The currency is pegged to the Euro at 1 EUR = 110.265 CVE, providing exchange rate stability for cross-border transactions.

Transfer Pricing — OECD Guidelines

Cabo Verde's transfer pricing rules follow the OECD Transfer Pricing Guidelines. The regulations require that transactions between related parties be priced at arm's length. Related parties include companies under common control, parent-subsidiary relationships, and individuals with significant influence. Documentation requirements include a master file and local file for groups meeting certain thresholds. Acceptable transfer pricing methods include the Comparable Uncontrolled Price (CUP) method, Cost Plus method, Resale Price method, Transactional Net Margin Method (TNMM), and Profit Split method. Advance Pricing Agreements (APAs) are available through DNRE. Penalties for non-compliance can be significant.

Withholding Taxes to Non-Residents

Payments to non-residents from Cabo Verde-source income are subject to withholding tax at the following standard rates (treaty rates may apply):

• Dividends — 10% (reduced to 10–15% under most DTTs)
• Interest — 15% (reduced to 10% under Portugal DTT)
• Royalties — 15% (reduced under DTTs)
• Management fees — 15%
• Technical service fees — 15%
• Rental income — 15% (non-resident landlords)

The person making the payment must withhold the tax and remit it to DNRE within 15 days. A withholding tax certificate must be issued to the non-resident.

CPLP Regional Framework

As a member of the Community of Portuguese Language Countries (CPLP), Cabo Verde benefits from preferential tax arrangements including:

• Preferential treatment — reduced WHT rates on dividends, interest, and royalties paid to residents of other CPLP member states
• Social security agreements — coordination of social security contributions with Portugal and other Lusophone countries
• CPLP trade agreements — preferential customs and trade arrangements within the community
• Double tax treaty network — comprehensive DTTs with Portugal, Angola, Mozambique, Guinea-Bissau, and São Tomé and Príncipe

CPLP member states are Angola, Brazil, Cabo Verde, Guinea-Bissau, Mozambique, Portugal, São Tomé and Príncipe, and Timor-Leste. Equatorial Guinea is an associate member.

Double Tax Treaties — Practical Application

Cabo Verde's double tax treaties follow the OECD Model Convention. To claim treaty benefits, a non-resident must:

• Obtain a Certificate of Tax Residency from the home country tax authority
• Submit a treaty relief application to DNRE
• Provide the certificate and application to the Cabo Verdean withholding agent
• Wait for DNRE approval (typically 2–4 weeks)

The Portugal-Cabo Verde treaty is the most significant, providing reduced rates on dividends (10–15%), interest (10%), and royalties (10%). Treaty benefits are available to residents of treaty countries who are the beneficial owners of the income. Cabo Verde has also signed treaties with China and Macau.

FAQs

Do I need to register for tax in Cabo Verde as a non-resident investor?

Non-residents earning Cabo Verde-source income subject to final withholding tax generally do not need to register. However, a non-resident with a permanent establishment in Cabo Verde must register and file corporate tax returns.

How do I claim a refund of excess WHT?

A non-resident may claim a refund if WHT was deducted at the full statutory rate when a reduced treaty rate should have applied. The refund claim is submitted to DNRE with supporting documents.

Does Cabo Verde have a General Anti-Avoidance Rule?

Yes, the CIR includes general anti-avoidance provisions that allow DNRE to recharacterise transactions entered into primarily for tax avoidance purposes.

Disclaimer

This guide provides general information about Cabo Verdean cross-border taxation for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Cabo Verdean international tax advisor or the Direção Nacional de Receitas do Estado for advice specific to your situation. InvestmentKit does not provide tax advice.