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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Guidance by country: Ethiopia: source of income

For the purposes of the credit Article (Elimination of double taxation), profits, income and gains derived by a resident of one of the countries which may be taxed in the other country in accordance with the provisions of the agreement are deemed to have their source in that other country (Article 22(6) and see INTM161120(c)).