DT6802 - Double Taxation Relief Manual: Guidance by country: Ethiopia: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Ethiopia is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject	Comments	Article
Portfolio dividends	10%	10
Dividends on direct investments	10%	10
Property income dividends	15%	10
Interest	5% (Note 1)	11
Royalties	7.5% (Note 2)	12
Government pensions	Taxable only in Ethiopia unless the individual is a resident, and national of, the UK.	19
Other pensions	Taxable only in the UK (Note 3)	18
Arbitration	No	N/A

Note 1: A zero rate applies where the interest is guaranteed or paid by:

a) Ethiopia or the UK or a political subdivision, local authority or administrative-territorial unit thereof; or

b) the Bank of England or the National Bank of Ethiopia.

Note 2: For the purposes of the Convention, “royalties” includes payments received as consideration for the use of, or the right to use, industrial, commercial or scientific equipment.

Note 3: Ethiopian State pensions are taxable only in Ethiopia.