← Taxation Fundamentals for Ethiopian Businesses: Strategic Tax Management

International Tax Considerations

Module 04 / 6 · 65 min

Handle payments abroad, permanent establishment, tax treaties and transfer pricing so cross-border dealings are taxed once and correctly.

In this module you will learn to

Apply the withholding and VAT rules to payments to non-residents and to imported services
Recognize when a foreign contractor creates a permanent establishment under the 91-day rule
Use tax treaties correctly and know when to confirm their status
Apply Transfer Pricing Directive No. 981/2024 and prepare a contemporaneous file
Explain the offshore indirect transfer rule and the tax on repatriated profit

Built on

Erudite Africa training curriculum: Taxation Fundamentals for Ethiopian Businesses, Level 3 Advanced, Strategic Tax Management (October 2026)
Income Tax Proclamation No. 979/2016 as amended by No. 1395/2025; Federal Income Tax Regulation No. 410/2017 as amended (2021); Transfer Pricing Directive No. 981/2024
Council of Ministers Investment Incentive Regulation No. 586/2026; Investment Proclamation No. 1180/2020; Special Economic Zone Proclamation No. 1322/2024; Directive No. 1064/2025
Federal Tax Administration Proclamation No. 983/2016 as amended by No. 1434/2026; Penalty Waiver Directive No. 189/2025; VAT Proclamation No. 1341/2024; Electronic Invoicing System Administration Directive No. 1142/2026
Capital Goods Leasing Business Proclamation No. 103/1998 as amended by No. 807/2013; Stamp Duty Proclamation No. 110/1998 as amended
Practitioner summaries of the 2025 and 2026 changes (PwC, KPMG, EY, Grant Thornton Ethiopia, 5A Law Firm, Ethio Alliance) where the gazetted text could not be read, as noted in the lessons

Examples and companies are fictional. Tax rates and rules are shown as they stood when the course was written; always check the current proclamations, directives and guidance from the Ministry of Revenues before filing, and take professional advice for your own case.