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Protocol to the Tax Treaty between Ethiopia and the Netherlands Signed

10 October 2014

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Treaty Development

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Ethiopia-Netherlands

According to recent reports, on 18 August 2014, a protocol to the 2012 income tax treaty between Ethiopia and the Netherlands was signed. The 2012 treaty is not yet in force. The protocol clarifies the taxation of dividends (Article 10), and adds limitation on benefits provisions (Article 21A). Under the limitation on benefits provisions, residents of either Contracting State will only be eligible for the reduced withholding tax rates provided by the articles on dividends, interest, and royalties when they are resident "qualified persons". Qualified persons include: An individual A contracting state, or a political subdivision or local authority thereof...