Egypt: Tax

تُعد الاتفاقية النموذجية لمنظمة التعاون الاقتصادي والتنمية (OECD Model Tax Convention on Income and on Capital) المرجع الأساسي الذي تستند إليه غالبية اتفاقيات تجنب الازدواج الضريبي المبرمة بين الدول، كما تمثل ال.

The OECD Model Tax Convention on Income and on Capital constitutes the primary reference upon which most bilateral tax treaties for the avoidance of double taxation are based. The accompanying OECD Commentaries serve as an essential interpretative source for understanding the meaning and application of the Convention’s provisions.

Repatriation of profits in Egypt is the question that matters most too foreign investors, and it usually arrives after the deal is done. Making money in Egypt is one thing. Moving it abroad in a clear, lawful...

Law No. 121 of 1982 regulates registration in the Importers Register and sets out the main requirements that natural and juristic persons must satisfy in order to import goods for trading purposes in Egypt. The law addresses key matters such as registration conditions, renewal procedures, amendment of registered data, deletion from the register, penalties, settlement of violations, and the role of the competent authority responsible for foreign trade affairs.

Transfer pricing has become one of the key areas of tax audits in Egypt as the Egyptian Tax Authority (“ETA”) continues aligning the Egyptian tax framework with OECD standards and international tax transparency requirements.

Egypt's Law 6 of 2025 introduces comprehensive tax incentives for SMEs with annual turnover up to EGP 20 million, while the Golden License system streamlines investment approvals into a single comprehensive permit.

Intra-group financing is a key area of international taxation, involving financial transactions between related companies across jurisdictions. A parent company may provide a loan to a subsidiary, or one subsidiary may provide financing to another group company. Because these transactions take place between related parties, the terms and conditions of the financing must be consistent with the Arm’s Length Principle.

Transfer pricing has become one of the key areas of tax audits in Egypt as the Egyptian Tax Authority (“ETA”) continues aligning the Egyptian tax framework with OECD standards and international tax transparency requirements.

Many multinational groups rely on Egyptian entities for R&D operations, engineering, software development, product testing, technical support, manufacturing improvements, and regional innovation functions. These activities often generate substantial commercial value and may contribute directly to the development or enhancement of intellectual property owned within the wider group.

Moving money out of Egypt is legally possible in many situations. The difficulty usually lies elsewhere: proving to the bank where the money came from, why it may leave Egypt, and whether the relevant tax and regulatory obligations have been dealt with.

Repatriation of profits in Egypt is the question that matters most too foreign investors, and it usually arrives after the deal is done. Making money in Egypt is one thing. Moving it abroad in a clear, lawful...

يواجه المستثمرون في مصر تساؤلًا قانونيًا جوهريًا حول الإطار التشريعي الأمثل لتأسيس