The income tax treaty between Ethiopia and Qatar was signed 10 April 2013. The treaty 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, and Qatari taxes on income.
The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services within a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 183 days in any 12 month period.
Both countries apply the credit method for the elimination of double taxation.
Article 28 includes a limitation on benefits provision. According to the provision, a resident of a contracting state will not receive the benefits or any reduction or exemption from tax provided for in the treaty if the main purpose or one of the main purposes of the resident or a connected person is to obtain the benefits of the treaty.
The treaty will enter into force once the ratification instruments are exchanged. It will apply in Ethiopia from 8 July next following the date of its entry into force, and in Qatar from 1 January of the year following its entry into force.
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