DT6803 | Double Taxation Relief Manual: Ethiopia: notes

Other income (Article 21)

Items of income not dealt with in any other Article of the Convention and arising in Ethiopia may be taxed in Ethiopia. All other items of income not dealt with in any other Article of the Convention and beneficially owned by a resident of the UK are not taxable in Ethiopia.

Tax spared (Article 22)

The Convention provides for credit in the UK for tax ‘spared’ (see INTM161270) in Ethiopia under the provisions of Ethiopian law set out in Article 22(3).

However, the Convention also provides that the relief shall not be given:

1. in respect of tax spared from income or profits arising or accruing more than 10 years after the date on which the Convention entered into force (21 February 2023); or

2. in respect of any income or profits which have benefitted from the exemption or reduction provided by the relevant Ethiopian laws for more than 10 years, whether or not the relief was first granted before the entry into force of the Convention.

Amounts of ‘tax spared’ for which relief is given should be reported as mentioned at INTM161290.