Cyprus: Treaty analysis: Cyprus – Ethiopia double tax agreement

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cyprus: Treaty analysis: Cyprus – Ethiopia double tax agreement

Nicolaou-Christiana

Christiana Nicolaou

Cyprus is continuing to develop its network of double taxation treaties (DTTs) through the signing of a new DTT with the Federal Democratic Republic of Ethiopia, on December 30 2015. The treaty is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital, and it was published with the official Cyprus Government Gazette on January 18 2016.

The signing of this agreement also verifies the Cyprus Government's efforts to strengthen trade and financial ties with the African continent, as another four DTTs are in force with African countries: South Africa, Mauritius, Seychelles and Egypt.

Main provisions of the Cyprus – Ethiopia DTT:

Among the key provisions of the newly-signed treaty are clauses specifying:

  • For royalties: the withholding tax on royalties will not be more than 5% of the gross royalties amount, if the recipient is the beneficial owner of the royalties.

  • For interest: the withholding tax on interest will not be more than 5% of the gross interest amount, if the recipient is the beneficial owner of the interest.

  • For dividends: the withholding tax on dividends will not be more than 5% of the gross dividends amount, if the recipient is the beneficial owner of the dividends.

Also, the permanent establishment (PE) definition within the treaty references a building site or construction or installation project being eligible to constitute a PE only if it lasts for more than six months.

Entry into force:

The DTT will be enforceable when both countries exchange notifications confirming that their official ratification procedures have been concluded, and the treaty provisions will have effect: i ) on or after January 1 following the date the treaty enters into force – for Cyprus; and ii) on or after July 8 following the date the treaty enters into force – for the Federal Democratic Republic of Ethiopia.

Christiana Nicolaou (christiana.nicolaou@eurofast.eu)

Eurofast Taxand Cyprus

Tel: +357 22 699 222

Website: www.eurofast.eu

more across site & bottom lb ros

More from across our site

PwC has taken the ‘remarkable position’ that a former partner was singularly responsible for its tax leaks scandal; in other news, Forvis Mazars unveiled its next UK CEO
Luxembourg saw the highest increase in tax-to-GDP ratio out of OECD countries in 2023, according to the organisation’s new Revenue Statistics report
Ryan’s VAT practice leader for Europe tells ITR about promoting kindness, playing the violincello and why tax being boring is a ‘ridiculous’ idea
Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems
A high number of granted APAs demonstrates the Italian tax authorities' commitment to resolving TP issues proactively, experts say
Malta risks ceding tax revenues to jurisdictions that adopt the global minimum tax sooner, the IMF said
The UK and what has been dubbed its ‘second empire’ have been found to be responsible for 26% of all countries’ tax losses by the Tax Justice Network
Ireland offers more than just its competitive corporate tax environment but a reduction in the US rate under a Trump administration could affect the country, experts tell ITR
The ‘big four’ firm was originally prohibited from tendering for government work until December 1 due to its tax leaks scandal, but ongoing investigations into the matter have seen the date extended
Approximately 74% of MAP cases in 2023 reached a full resolution, but new transfer pricing MAP cases fell by 16%
Gift this article