The income tax treaty between Ethiopia and Poland was signed 23 July 2015. The treaty is the first of its kind between the two countries and will enter into force after the ratification instruments are exchanged.
The treaty covers Ethiopian tax on income and profit, and tax on income from mining, petroleum and agricultural activities. It covers Polish personal income tax and corporate income 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.
Both countries apply the credit method for the elimination of double taxation.
The treaty includes a limitation on benefits provision (Article 28), which states that the benefits of the treaty will not be available if the main purpose or one of the main purposes for entering into an arrangement was to obtain the benefits that would not otherwise be available.
The treaty will enter into force three months following the exchange of the ratification instruments, and will apply in Ethiopia from 8 July next following the date of its entry into force and in Poland from 1 January of the year following its entry into force.
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