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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Agreement shall apply to taxes on income on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises.

(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) In the case of the United Arab Emirates:
    • (i) the income tax; and
    • (ii) the corporation tax;
  • (hereinafter referred to as "UAE tax");
  • (b) In the case of Ethiopia:
    • (i) the tax on income and profit; and
    • (ii) the tax on income from mining, petroleum and agricultural activities;
  • (hereinafter referred to as "Ethiopian tax").

(4) This Agreement shall apply also to any identical or substantially similar taxes, which are imposed under the laws of a Contracting State after the date of signature of this Agreement in addition to, or in place of, the existing taxes referred to in paragraph (2). The competent authorities of the Contracting States shall notify each other of any substantial changes, which have been made in their respective taxation laws.