Cyprus: Treaty analysis: Cyprus – Ethiopia double tax agreement

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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 & shared bottom lb ros

More from across our site

As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi model databases – is quietly transforming intercompany pricing logic
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
AI will mean fewer entry-level roles in tax but also the emergence of new jobs, according to tax expert Isabella Barreto
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
Overall revenues and average profit per partner also increased in the UK, the ‘big four’ firm revealed
Gift this article