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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Ethiopia: interest

Where the beneficial owner of interest arising in Ethiopia is a resident of the United Kingdom, the agreement limits the tax payable in Ethiopia to a rate not exceeding 5% of the gross amount.

However, no taxes are payable on interest arising in Ethiopia where the beneficial owner is the United Kingdom Government, a political sub-division thereof, a local authority or the Bank of England.

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