Ethiopia

Under the local tax legislation, a resident for tax purposes is a body incorporated in Ethiopia. A resident also includes a body incorporated overseas that has a place of effective management in Ethiopia at any time during the tax period.

Permanent establishment (PE)

A business carried out wholly or partly through a fixed place of business or an exploration/extraction of mineral resources (a mine, oil or gas well, etc.) will give rise to a PE in Ethiopia. The definition of PE in the local tax legislation also includes a service PE and dependent agent PE concepts.

A service PE arises through furnishing of services by a person through employees or any other personnel engaged by the person where the activities on the same project or connected projects continue for more than 183 days in a one-year period. On the other hand, a dependent agent that habitually concludes contracts on behalf of a person triggers a PE.