16/04/2026
Invest in Mozambique via Macau: Your Gateway to 16 SADC Markets
On the occasion of the State Visit of the President of Mozambique to China (17 April 2026), BN Lawyers presents a comprehensive guide on how to use Macau as a strategic platform to invest in Mozambique and access the entire SADC region – with tax benefits, rules of origin advantages, and the US$1 billion China-Portuguese Speaking Countries Cooperation and Development Fund.
1. Macau’s Role: Economic Platform Between China and Portuguese-Speaking Countries
• Tax exemption on dividends from Mozambique companies
• Tax exemption on interest and income from debt securities issued in Macau
• Double Taxation Avoidance Agreements: Macau-China & Macau-Mozambique
2. Why Mozambique?
• Trade with China: US$1.6B exports (coal, timber) / US$3.1B imports (machinery, electronics, vehicles)
• Market access: duty-free access to SADC (Southern African Development Community)
• Commonwealth membership
3. SADC: Gateway to 16 Markets
• 16 member states, 253 million people, USD 563 billion GDP
• Strategic ports: Maputo (serving South Africa, Eswatini, Zimbabwe), Beira (Malawi, Zambia, Zimbabwe), Nacala (Malawi, Zambia)
• Three major transport corridors
Selected Member States & Key Industries:
South Africa (largest economy), DRC (mining, consumer goods), Tanzania (natural gas, agriculture), Zambia (copper), etc.
4. University Partnerships: Meeting the 35% Local Content Requirement. BN Lawyers partners with leading Mozambican universities to:
• Employ local graduates
• Establish local R&D and processing facilities
• Achieve regulatory compliance while creating social impact
5. Investment Structure: The Macau SPV Model
• Chinese Company → Macau SPV → Mozambique Operating Companies
• Macau SPV holds capital of Mozambique subsidiaries
• Financing via CPDFund or bilateral facility agreements
• Security: pledge of SPV’s shares in operating companies
• Maximises tax efficiency, legal certainty, and access to dedicated China-PSC funding
6. Macao Forum CPDFund (China-Portuguese Speaking Countries Cooperation and Development Fund) - USD 1 billion
• Launched 2013 by China Development Bank & Macao Industrial and Commercial Development Fund
• Managed by CADFund (headquartered in Macau since 2017)
• Priority sectors: infrastructure, energy, agriculture, technology
• Investment types: equity, quasi-equity, fund-of-funds
Selected investments:
• Mozambique Agricultural Park
• Angola power transmission & water supply equipment
• Brazil CSI PV plant, S**C São Simão hydroelectric project, CMP Paranaguá container terminal
• Cross-regional clean energy & ICBC debt securities for Portuguese-speaking African countries
BN Lawyers: Your Legal Partner for China-Mozambique Investment
Macau-based, specialising in bridging Lusophone world and Chinese market
Services: incorporation, investment structuring, IP protection, dispute resolution
✉️: Bruno Nunes: [email protected] 🌐: www.bnlawmacau.com