The tax treaty between Ethiopia and Seychelles was signed 14 July 2012. The agreement is the first of its kind between the two countries, and has not yet entered into force.
The treaty covers Ethiopian tax on income and profits, and the tax on income from mining, petroleum and agricultural activities. It covers Seychelles business tax, income and non-monetary benefits tax, and petroleum income tax.
The treaty includes the provision that technical fees will be subject to withholding tax at a rate of up to 7.5%. Technical fees are defined as payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature.
Both countries apply the credit method for the elimination of double taxation.
The treaty will enter into force once the ratification instruments are exchanged. It will apply for Seychelles from 1 January of the year following its entry into force, and will apply for Ethiopia from 8 July following its entry into force.
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