Egypt International Tax and Transfer Pricing Review
Information current to: 27 September 2026
Currency and tax year: Egyptian pound (EGP); tax period is generally the financial year used by the taxpayer.
Executive summary
Egypt's general corporate income-tax rate is 22.5% of annual net profits, with specified sectors subject to higher rates. Domestic withholding on non-resident interest, royalties and service fees is generally 20% of gross amounts; dividends are generally subject to 10%, reduced to 5% where the statutory participation and holding-period conditions are satisfied. Treaties can alter these outcomes. The Income Tax Law includes a related-party arm's-length rule, while the Unified Tax Procedures Law establishes master-file, local-file and CbC reporting obligations.
The primary law has been amended, including by Law 151/2026. Since the saved materials are not consolidated and the 2026 amendment is recent, confirm its effective dates and any changes to the provisions being applied. Separate domestic withholding from treaty entitlement and retain evidence before payment.
1. Legal framework and scope
The main statute is Income Tax Law 91/2005, together with its Executive Regulations and the Unified Tax Procedures Law 206/2020. The Egyptian Tax Authority's legislation index lists Law 151/2026 amending the Income Tax Law, and Law 7/2025 amending the Unified Tax Procedures Law. The saved source materials do not form a single consolidated current text. The ordinary corporate rate under Article 49 is 22.5%; specified entities, including certain petroleum-related businesses, are subject to special rates. This review covers corporate income tax, international tax and transfer pricing only; VAT, customs, foreign exchange, sanctions and individual taxes are outside scope.
Resident companies are generally taxable on profits, while non-resident businesses are subject to Egyptian tax on relevant Egyptian-source income and profits attributable to a permanent establishment. Article 68 and following address relief for foreign tax, subject to domestic rules and treaty provisions. Confirm whether the 2026 amendments affect the taxpayer, period or relief being claimed.
2. Permanent establishment and taxable nexus
Article 49 addresses the taxation of permanent establishments and Article 48 contains corporate residence rules. Test domestic residence/source provisions alongside the relevant treaty's PE definition. Review premises, project duration, dependent agents, local personnel and contract activities. If an Egyptian PE exists, assess registration, attribution of profits, deductions, return filing and withholding responsibilities.
3. Withholding tax and cross-border payments
| Payment | Domestic starting point | Treaty and practical point |
|---|---|---|
| Dividends | Generally 10%; 5% may apply where participation exceeds 25% and the shares are held for at least two years, subject to statutory terms. | Check the recipient, holding period, treaty rate and any exemption. |
| Interest | Generally 20% of gross payments to non-residents under Article 56. | Confirm source, any statutory exclusion and treaty limitation. |
| Royalties | Generally 20% of gross payments to non-residents under Article 56. | Distinguish a licence from services and check treaty definitions. |
| Services | Generally 20% for covered non-resident service payments under Article 56. | Determine if services are covered, whether a PE exists, and whether treaty relief is available. |
Article 56 applies without deduction of costs to specified payments by Egyptian residents and non-resident bodies with an Egyptian PE to non-residents. The actual statutory text and treaty must be checked for the particular payment; do not apply one rate indiscriminately to mixed contracts.
4. Royalties, software and services
Separate IP rights, know-how, software access, cloud hosting, implementation and support. The legal rights granted and the actual work performed can change both domestic classification and treaty treatment. Preserve contracts, deliverables, IP ownership and rights, place-of-performance evidence, invoices and allocation of bundled consideration.
5. Treaties and double-tax relief
Check the applicable bilateral treaty for business profits, PE, dividends, interest and royalties, and confirm the recipient's residence and beneficial ownership. Egypt's domestic foreign-tax relief provisions should be read with the treaty and the income to which the foreign tax relates. Keep tax certificates and calculation workpapers. Do not assume treaty relief is automatic at source; confirm the ETA process and required documentation.
6. Transfer pricing
Article 30 of Income Tax Law 91/2005 provides the domestic arm's-length basis for related-party transactions. The Egyptian Transfer Pricing Guidelines explain the ETA's approach and recognize the OECD methods, including CUP, resale price, cost plus, TNMM and profit split, selected according to the facts and reliable comparables.
Articles 12–13 of Unified Tax Procedures Law 206/2020 require master-file, local-file and CbC documentation for in-scope related-party commercial or financial transactions. The OECD's Egypt country profile describes the statutory filing timing, but it predates later amendments. Confirm current thresholds, deadlines, penalties and any changes under Laws 7/2025 and 150/2026 before filing. The ETA publishes the guidelines and unilateral APA forms; check eligibility and procedure directly with the Authority.
7. Priority actions
- Reconcile Income Tax Law 91/2005 with Laws 30/2023, 7/2024 and 151/2026 and the applicable Executive Regulations.
- Test domestic and treaty PE status for local projects, personnel and agents.
- Apply withholding by payment category and recipient facts; document treaty claims before remittance.
- Confirm current TP file thresholds, filing calendar and penalties under the amended procedural law.
Sources reviewed
- Egyptian Tax Authority, Income Tax Laws — Law 91/2005.
- Egyptian Tax Authority, current income-tax legislation index — includes Law 151/2026 and prior amendments.
- Egyptian Tax Authority, Transfer Pricing Guidelines — official guidance and APA forms.
- OECD, Egypt Transfer Pricing Country Profile — cross-check for documentation mechanics; updated June 2022, not a substitute for current law.