background image
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.

PROTOCOL

PROTOCOL TO THE AGREEMENT BETWEEN THE FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA AND THE UNITED ARAB EMIRATES FOR THE AVIODANCE OF DOUBLE TAXATION AND THE PREVENSTAION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

On signing of the Agreement between the Federal Democratic Republic of Ethiopia and the United Arab Emirates for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (hereinafter referred to as the "Agreement"), the undersigned have agreed that the following provisions of this protocol shall form an integral part of the Agreement.

For the purpose of paragraph (3) of Article 12 it is understood that sovereign wealth fund managing agencies shall include:

  • (a) in the case of UAE:
    • (i) Central bank of UAE;
    • (ii) Abu Dhabi Investment Authority;
    • (iii) International Petroleum Investment Corporation (IPIC);
    • (iv) Investment Corporation of Dubai, Emirates Investment Authority;
    • (v) Mubadela;
    • (vi) Dubai World and Pension Fund; and
    • (vii) any other institution which is wholly or substantially owned by the Federal or local governments of UAE
  • (b) in the case of Ethiopia:
    • (i) The National Bank of Ethiopia;
    • (ii) Construction and Business Bank of Ethiopia;
    • (iii) Development Bank of Ethiopia;
    • (iv) Pension Funds of Ethiopia; and
    • (v) Any other institution which is wholly or substantially owned by the Federal or Regional Governments of Ethiopia.

IN WITNESS WHEREOF, the undersigned dully authorized by their respective Governments, have signed this protocol.

DONE at Abu Dhabi on the 12th day of April, 2015 in two originals in Arabic and English language, the two texts being equally authentic. In case of divergence of interpretation, the English text shall prevail.

FOR THE GOVERNMENT OF THE FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA:

H.E. TEDROS ADHANOM

GHEBREYESUS (PHD)

MINISTER OF FOREIGN AFFAIRS

FOR THE GOVERNMENT OF THE UNITED ARAB EMIRATES:

ABDULLAH BIN ZAYED

MINISTER OF FOREIGN AFFAIRS