Egypt: Transfer Pricing

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.

In recent years, the world has witnessed a tremendous development in artificial intelligence technologies, so that it is no longer just a technical tool used to improve some processes within companies, but has become a key element in creating economic value and generating revenue.

شهد العالم في السنوات الأخيرة تطوراً هائلاً في تقنيات الذكاء الاصطناعي، حتى لم يعد مج&

Digital assets have emerged as one of the fundamental transformations in the digital economy, providing artists, game developers, and multinational corporations with extensive opportunities to generate financial returns from digital assets on a global scale.

In the age of globalization, commercial dumping is no longer a one-way phenomenon flowing from foreign producers toward domestic markets.

Transfer pricing challenges have become one of the most significant and pressing issues in modern tax administration. It is no longer perceived as a purely technical...

Transfer pricing refers to the rules and methods for pricing transactions between Related parties or entities under common ownership or control.