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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Guidance by country: Ethiopia: tax spared

The Agreement provides for credit in the UK for tax ‘spared’ (see INTM161270) in Ethiopia under the provisions of Ethiopian law set out in Article 22(3).

However, the Agreement also provides that the relief shall not be given:

  1. in respect of tax spared from income or profits arising or accruing more than 10 years after the date on which the Agreement entered into force (21 February 2023); or
  2. in respect of any income or profits which have benefitted from the exemption or reduction provided by the relevant Ethiopian laws for more than 10 years, whether or not the relief was first granted before the entry into force of the Agreement.

Amounts of ‘tax spared’ for which relief is given should be reported as mentioned at INTM161290.