Ethiopia Rewrites the Rules on Amended Assessments, Limitation Periods, and New Evidence

In Part One of this series, we examined the conciliation regime introduced by Proclamation No. 1434/2026, the Tax Administration (Amendment) Proclamation published in the Federal Negarit Gazette on 30 July 2026. In this Part Two, we turn to a cluster of changes that will affect every taxpayer under audit, every practitioner preparing an objection, and every adviser assessing the exposure of a client to a reopened assessment. The amendment reworks the limitation periods governing amended assessments, extends the look-back period for suspected tax fraud to ten years, inserts a new statutory code on the revision of assessments, tightens the rules on the presentation of new evidence and attaches a ten per cent penalty to the late production of material documents, and creates a conditional tax clearance certificate whose legal effect is deliberately limited. Please read the full details in the attachment.