Taxation Fundamentals for Ethiopian Businesses: Strategic Tax Management

What you will be able to do

• Separate legal tax planning from avoidance and evasion, and build every plan on substance, documentation and a real business purpose
• Model the corporate tax position of a company or group, including the 2.5% minimum alternative tax, advance tax and the investment incentives under Regulation No. 586/2026
• Run a tax health check, rate tax risks in a register and carry out tax due diligence on an acquisition target
• Compare debt, equity, leasing and buying on an after-tax basis, applying the interest, dividend, depreciation and leasing rules
• Manage cross-border payments, permanent establishment, tax treaties and transfer pricing under Directive No. 981/2024
• Choose between share and asset acquisitions and plan reorganizations that qualify for relief and survive the anti-avoidance tests

Capstone project

Tax strategy and tax due diligence report for Tekeze Industrial Group

Prepare a tax strategy and tax due diligence report for Tekeze Industrial Group PLC, or for your own company or a client if you have the data, using the tax-planning-model.xlsx workbook. You run a tax health check of the group, build a risk register, carry out tax due diligence on the Ziway Edible Oil acquisition, compare financing and structure options after tax, and finish with an action plan the board can approve. Every recommendation must be legal tax minimization only, built on substance and documents, with the MAT test applied, and every figure you could not confirm in the law must be marked for confirmation with the Ministry of Revenues or a tax adviser.

1. 1Health check: complete the Health Check sheet for each group company and tax type, rating each area Green, Amber or Red with the evidence, and reconcile turnover in the accounts to the VAT returns.
2. 2Risk register: list every issue from the health check and the Ziway due diligence with its gross tax, likelihood, weighted amount, evidence, owner and deadline, and add interest where the payment is late.
3. 3Financing: compare debt, equity and the FZE shareholder loan for the pasta line on the Debt vs Equity sheet, and the truck options on the Lease vs Buy sheet, each with the MAT test.
4. 4Incentives: model the Tekeze Agro-Processing application and the Packaging election on the Incentive Comparison sheet, year by year, with MAT as the floor and only targets the business plan supports.
5. 5Transfer pricing and the deal: complete the transfer pricing checklist for the FZE fee and loan, and the acquisition checklist for Ziway, and compare a share deal with an asset deal.
6. 6Report: write a 6 to 10 page report with an executive summary, the health check results, the risk register, the financing and structure options with after-tax comparison, and a 12-month action plan with owners and dates.

What you hand in

• The completed tax-planning-model.xlsx workbook: Health Check and Risk Register, Debt vs Equity, Lease vs Buy, Incentive Comparison, Transfer Pricing Checklist and Acquisition Due Diligence sheets
• A 6 to 10 page tax strategy and due diligence report with an executive summary, risk register, options comparison and 12-month action plan
• A one-page board summary listing the decisions requested, their after-tax effect and the facts still to be confirmed