The income tax treaty between Ethiopia and Ireland entered into force on 12 August 2016. The treaty, signed 3 November 2014, is the first of its kind between the two countries.
The treaty covers Ethiopian tax on income and profit, and the tax on income from mining, petroleum and agricultural activities. It covers Irish income tax, universal social charge, corporation tax and capital gains tax.
The following capital gains derived by a resident of one Contracting State may be taxed by the other State:
Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.
Article 23 (Miscellaneous Rules Applicable to Certain Offshore Activities) includes the provision that a permanent establishment will be deemed constituted if an enterprise carries on offshore activities in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in a Contracting State for a period or periods aggregating more than 30 days within any 12-month period.
Both countries generally apply the credit method for the elimination of double taxation.
The treaty applies in Ethiopia from 8 July 2017 and in Ireland from 1 January 2017.
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