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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Guidance by country: Ethiopia: royalties

Where the beneficial owner of royalties arising in Ethiopia is a resident of the United Kingdom, the agreement limits the tax payable in Ethiopia to a rate not exceeding 7.5% of the gross amount.

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

For the purposes of the Agreement, “royalties” includes payments received as consideration for the use of, or the right to use, industrial, commercial or scientific equipment.