Skip to content
Erudite AfricaCenter of Excellence
← Negotiation and Deal Structuring

Ethiopian legal, FX and tax constraints, and risk allocation

Module 03 / 5 · 65 min

Work within Ethiopian company law, foreign ownership rules, FX and repatriation rules and tax on transfers, and allocate risk through warranties, indemnities, MAC clauses and conditions.

In this module you will learn to

  • Explain how the choice between a share company and a PLC affects structuring
  • Check foreign ownership access and minimum capital before structuring a deal
  • Apply FX rules on external loans and repatriation of dividends and proceeds
  • Identify the tax points on share transfers, dividends, indirect transfers and related-party payments
  • Draft and negotiate warranties, indemnities, MAC clauses and FX and regulatory risk sharing

Built on

  • Erudite Africa course specification: 3.h Negotiation and Deal Structuring, Levels 1 and 2 (October 2026), extended to Advanced depth
  • Erudite Africa: Training Module, Ethiopian Context, programme overview and regulatory register (October 2026)
  • Investment Proclamation No. 1180/2020, Investment Regulation No. 474/2020 and Investment Board Directive No. 1082/2025
  • NBE directives as listed in the lessons: FXD/01/2024, FXD/04/2026, SBB/87/2024, SBB/92/2024
  • Income Tax Proclamation No. 979/2016 as amended by No. 1395/2025, and Transfer Pricing Directive No. 981/2024
  • Commercial Code Proclamation No. 1243/2021, Arbitration and Conciliation Working Procedure Proclamation No. 1237/2021, Capital Market Proclamation No. 1248/2021 and the ESX Rulebook (December 2024), as cited in the specification

Examples and companies are fictional. Bank practices are shown as typical Ethiopian practice, not as any one bank's policy. Always apply your own institution's approved policy and the current NBE directives.