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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Guidance by country: Ethiopia: dividends

Where the beneficial owner of a dividend is a resident of the United Kingdom, withholding tax at a rate not exceeding 15% is payable if the dividend is paid out of the property income of an Ethiopian investment vehicle equivalent to a United Kingdom Real Estate Investment Trust.

All other dividends beneficially owned by residents of the UK are taxable in Ethiopia at a rate not exceeding 10%.

The reduced rates provided by the treaty are not given if the dividend is effectively connected (see INTM153110 eighth sub-paragraph) with a permanent establishment which the United Kingdom resident recipient has in Ethiopia.