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12996 Ethiopia - Agreement to Exempt from Income Tax, on a Reciprocal Basis, Income Derived from the International Operation of Aircraft and Ships


   
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TREATIES AND OTHER INTERNATIONAL ACTS SERIES 12996

 

 

TAXATION

Shipping and Aircraft

 

 


Agreement Between the
UNITED STATES OF AMERICA
and ETHIOPIA

 

Effected by Exchange of Notes
Dated at Addis Ababa October 30 and
November 12, 1998

 

 

 

 

 

 

 

 

 

 

 

 

NOTE BY THE DEPARTMENT OF STATE

Pursuant to Public Law 89—497, approved July 8, 1966
(80 Stat. 271; 1 U.S.C. 113)—

“. . .the Treaties and Other International Acts Series issued
under the authority of the Secretary of State shall be competent
evidence . . . of the treaties, international agreements other than
treaties, and proclamations by the President of such treaties and
international agreements other than treaties, as the case may be,
therein contained, in all the courts of law and equity and of maritime
jurisdiction, and in all the tribunals and public offices of the
United States, and of the several States, without any further proof
or authentication thereof.”

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ETHIOPIA

Taxation: Shipping and Aircraft


Agreement effected by exchange of notes
Dated at Addis Ababa October 30 and
November 12, 1998;
Entered into force November 12, 1998;
Effective January 1, 1998.

No. 600
The Embassy of the United States of America
presents its compliments to the Ministry of Foreign
Affairs of the Federal Democratic Republic of Ethiopia
and has the honor to send to the Ministry a corrected
version of the diplomatic note no. 254 dated May 29,
1998. The Government of the United States of America
and the Government of the Federal Democratic Republic
of Ethiopia conclude an agreement to exempt from
income tax, on a reciprocal basis, income derived by
residents of Ethiopia and the United States from the
international operation of aircraft and ships. The
terms of the agreement are as follows:
The Government of the United States of America,
in accordance with sections 872 (b) and 883 (a) of the
Internal Revenue Code, agrees to exempt from tax gross
income derived from the international operation of
aircraft and ships by Ethiopian residents and
corporations organized in Ethiopia. This exemption is
granted on the basis of equivalent exemptions granted
by the Government of Ethiopia to United States
individual residents and to corporations organized in
the United States.
In the case of Ethiopian corporation, the
exemption shall apply only if the corporation meets
the ownership or public trading requirements of
Ethiopia.
Gross income includes all income derived from the
international operation or chartering of aircraft or
ships, including: a) income from the rental on a
full (time or voyage) basis of ships or aircraft used
in international transport; b) income from the rental
on a bareboat basis of ships or aircraft used in
international transport; c) income from the rental
of containers and related equipment used in
international transport that is incidental to income
from the international operation of ships or aircraft;
and d) gains from the sale or other alienation of
ships or aircraft used in international transport by a
person primarily engaged in the international
operation of ships or aircraft.
If the proposals set out above are acceptable to
the Government of the Federal Democratic Republic of
Ethiopia, the Embassy, on behalf of the Government of
the United States of America, proposes that this Note
together with the Government of Ethiopia's note in
reply, shall constitute an agreement between the
Government of the United States of America and the
Government of the Federal Democratic Republic of
Ethiopia which shall enter into force on the date of
the Government of the Federal Democratic Republic of
Ethiopia's reply, and shall have effect with resect to
taxable years beginning on or after January 1, 1998.
3
The Embassy of the United States of America
avails itself of this opportunity to renew to the
Ministry of Foreign Affairs of the Federal Democratic
Republic of Ethiopia the assurances of its highest
consideration.
Embassy of the United States of America
Addis Ababa, October 30, 1998
CC: Ato Hiruy Amanuel
Europe and Americas General Directorate
Ministry of Foreign Affairs

The Federal Democratic Republic of Ethiopia

MINISTRY OF FINANCE
AMI/28/194
Ref No.
12 NOV 1998
Date
Embassy of the United States of America
Addis Ababa
The Ministry of Finance of the Federal Democratic Republic of Ethiopia presents its
compliments to the Embassy of the United States of America and has the honor to refer to your
letter of 29th of May 1998; and we reply to the contents of the letter hereinabove mentioned.
We are glad to inform you that the Ministry of Finance, on behalf of the Federal
Democratic Republic or Ethiopia, accepts the terms as detailed in your letter granting exemptions
to income derived from the International operation of aircraft and ships and we do extend the
same for aircraft and ships of the United States of America residents and corportions organized in
the United States of America under the same term, in so far as such ships and aircrafts meet the
requirements of directives and other regulations issued by the Ministry of transport and
communications under Article 18(5) of the Definition of Powers and Duties of the Executive
Organs of the Federal Democratic Republic of Ethiopia proclamation No. 4/1995.
This consent shall come into effect on the dates indicated in your letter of proposal.
The Ministry of Finance avails itself of this opportunity to assure to your Excellency its
highest consideration and cooperation in this and other matters.
Sufian Ahmed
Minister
CC:
Ato Hiruy Amanuel, Director General,
European and Americas General Directorate,
Ministry of Foreign Affairs
Addis Ababa



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