Details of the Ethiopia-Netherlands income tax treaty, signed on 10 August 2012 have become available. The treaty generally follows theOECD Model, but some provisions are based on the UN Model (2001).
The maximum rates of withholding tax are:
|-||5% on dividends if the receiving company owns at least 10% of the capital of the company distributing the dividends. Otherwise, the domestic rates apply, i.e. 10% for Ethiopia and 15% for the Netherlands;|
|-||5% on interest; and|
|-||5% on royalties;|
The treaty provides that Ethiopia will not tax payments for technical services unless those payments can be allocated to a PE.
A building site or construction, assembly or installation project or supervisory activity connected therewith constitutes a PE if such site, project or activities continue for a period of more than 6 months.
The treaty provides for arbitration.
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