Article 24 — Supply of Services in Ethiopia

1/ Subject to Sub-Article (2) of this Article, a supply of services shall occur in Ethiopia if the place of business of the supplier from which the services are supplied is in Ethiopia. 2/ Despite Sub-Article (1) of this Article, a supply of services, other than a reverse charged supply, by a person who carries on business outside Ethiopia and does not have a fixed place of business in Ethiopia shall occur in Ethiopia if. a) the services are physically performed in Ethiopia by a person who is in Ethiopia at the time of the supply, (b) the services relate to immovable property in Ethiopia; (c) the services are remote services supplied to a resident of Ethiopia as determined under Sub-Article (3) of this Article, (d) the services are a supply of an inbound tourism product, or agency or booking services relating to a supply of an inbound tourism product; (e) the services are telecommunications services that can be used only in Ethiopia; or (f) except where Paragraph (e) of this Sub-Article applies, the services are telecommunication services where the mobile country code of the International mobile subscriber identity stored on the subscriber identity module card used by the recipient is Ethiopia. 3/ For the purposes of Sub-Article (2) Paragraph (c) of this Article and subject to Sub-Article (4) of this Article, a recipient of a supply of remote services shall be treated as a resident of Ethiopia if at least Two of the following apply: a) the recipient’s billing address is in Ethiopia; b) the recipient’s bank account is in Ethiopia, including the account the recipient uses for payment or the billing address held by the bank; c) the recipient’s fixed land line through which the service is supplied to the recipient is in Ethiopia; d) the mobile country code of the International mobile subscriber identity stored on the subscriber identity module card used by the recipient is Ethiopia; e) the internet protocol address of the device used by the recipient or another geolocation method is in Ethiopia; or f) any other commercially relevant information indicates that the recipient is resident in Ethiopia. ‹‹ 4/ If there are Two factors on the list in Sub- Article (3) of this Article supporting that the recipient is a resident of Ethiopia and Two factors supporting residence in another country, the supplier shall determine the recipient’s residence based on the factors that, in the circumstances, are the most reliable indicators of the recipient’s residence. 5/ For the purposes of Sub-Article (4) of this Article, the factors in Sub-Article (3) of this Article are listed in order of reliability starting with the most reliable. 6/ Having established that the recipient of a supply is a resident of Ethiopia under Sub-Article (3) of the Article, Unless the beneficiary of the service is notified under Article 65 of this Proclamation, the beneficiary of the service must be deemed irrelevant to the tax collected by the purchaser regarding the supply.