India has signed a Double Taxation Avoidance Agreement (DTAA) with Ethiopia to check tax evasion and facilitate exchange of banking information.
The agreement was signed by External Affairs minister S M Krishna and Ethiopia’s minister of Finance and Economic Development Sufian Ahmed, in the presence of Prime Minister Manmohan Singh and his Ethiopian counterpart Meles Zenawi.
Besides facilitating economic cooperation between the two countries, the agreement will help prevent “fiscal evasion with respect to taxes on income,” an official release said.
The agreement would also allow effective exchange of information, including banking data, and assistance in collection of taxes.
It incorporates anti-abuse provisions to ensure that the benefits of the agreement are availed of by the genuine residents of India and Ethiopia.
The DTAA provides that business profits will be taxable in the source State if the activities of an enterprise constitute a permanent establishment in the source State. Examples of permanent establishment include a branch, factory, etc. Profits of a construction, assembly or installation projects will be taxed in the State of source if the project continues in that State for more than 183 days.
Profits derived by an enterprise from the operation of ships or aircrafts in international traffic shall be taxable in the country of residence of the enterprise. Dividends, interest, royalties and fees for technical services income will be taxed both in the country of residence and in the country of source. However, the maximum rate of tax to be charged in the country of source will not exceed 7.5% in the case of dividends and 10% in the case of interest, royalties and fees for technical services. Capital gains from the scale of shares will be taxable in the country of source.
The Agreement further incorporates provisions for effective exchange of information and assistance in collection of taxes between tax authorities of the two countries in line with internationally accepted standards including exchange of banking information and incorporates anti-abuse provisions to ensure that the benefits of the Agreement are availed only by the genuine residents of the two countries.
The Agreement will provide tax stability to the residents of India and Ethiopia and facilitate mutual economic cooperation as well as stimulate the flow of investment, technology and services between India and Ethiopia.
