Egypt: local rules

Article 30 of Income Tax Law No. 91 of 2005 lets the Egyptian Tax Authority (ETA) set taxable profit at the arm's length price when related enterprises agree terms that differ from independent ones and that cut the tax base or shift the tax burden to an exempt or non-taxable enterprise. Articles 38 to 40 of the Executive Regulations, rewritten by a Minister of Finance decree of May 2018, say what ETA may check and list the methods. Related persons include spouses and relatives in the direct line, a company and anyone who holds at least 50% of its shares or voting rights, partnerships and their partners, and companies that share a 50% holder. Law No. 30 of 2023 is reported to have changed the definition of a related person, so check the wording against the current text. The rules cover Egyptian-to-Egyptian deals as well as cross-border deals. The ETA Egyptian Transfer Pricing Guidelines (October 2018) explain the rules but the Arabic text prevails over the English one.

Article 12 of the Unified Tax Procedures Law No. 206 of 2020 requires every person with deals with related persons to give ETA a master file, a local file and, where it applies, a country-by-country report. Article 13 sets the timing: the local file within two months of filing the annual return, the master file by the date the parent files its master file in its own country (if that country sets no date, ETA's practice is the local file date) and the CbC report within one year of the end of the tax year. Related party deals must also be listed in the corporate return (Table 508). The statute exempts a person whose related party deals do not exceed EGP 8m in the tax period from the master and local file, and lets the Minister raise that figure. It was raised to EGP 15m by Decree 52 of 2024 and then to EGP 30m by a decision of December 2025, reported as Decision 534 of 2025. Records are kept for five years from the filing deadline (Income Tax Law art. 91, as quoted in the Guidelines). The arm's length rule still applies below the threshold. Documents may be in English but ETA can ask for an Arabic translation.

Five methods are approved: comparable uncontrolled price, cost plus, resale price, profit split and transactional net margin. The Guidelines ask taxpayers to pick the most appropriate method for each deal. If none of the five can be used, another method may be used if records show it is suitable (Executive Regulations art. 40). Before 2018 the comparable uncontrolled price method had first priority, but the 2018 text no longer says so. A range of results is accepted. The Guidelines' examples use the interquartile range and an adjustment to the median when a result falls outside it. The Guidelines describe unilateral, bilateral and multilateral advance pricing agreements but give detailed steps only for unilateral ones. A request is made to ETA's transfer pricing department at least six months before the first covered year, and an annual compliance report is due within 60 days of filing the return. A new benchmarking search is advised every three years with yearly financial updates.

Article 13 of Law 206 of 2020 sets a payment equal to a share of related party deal value: 1% for deals not shown in the return, 3% for a missing local file, 3% for a missing master file and 2% for a missing CbC report or notification. The total cannot go above 3% of deal value. ETA's Explanatory Instructions No. 78 of 2023 say these amounts do not carry the late payment charge under art. 110 of the Income Tax Law. Late filing of the return itself costs EGP 3,000 to 50,000 plus the tax if it is up to 60 days late, and EGP 50,000 to 2m if it is more than 60 days late (arts. 69 and 70 of Law 206), with higher amounts for repeat offences. If documents are missing, ETA may set its own pricing rules, and the taxpayer can object and appeal (art. 12).

No Pillar Two law has been enacted in Egypt and no draft law was found as of 27 October 2026. Egypt is an OECD Inclusive Framework member. The Finance Ministry has been reported since late 2024 to be studying a 15% minimum tax, but nothing has been put before the House of Representatives. There is no registration or return deadline.

Egypt's weekly rest days for government offices are Friday and Saturday. The tool moves a deadline only off Fridays and official holidays, because it is not settled that a Saturday counts as an official holiday under Article 18 of the Civil and Commercial Procedures Law (see below). The annual return for companies is due before 1 May of each year or within four months after the financial year ends (art. 31(c) of Law 206), so 30 April for a 31 December year end. It is filed online and the tax is paid the day it is filed (art. 32). ETA twice treated deadlines that fell in a holiday as moving to the next working day (Eid al-Fitr 2025, and Eid al-Adha 2026 when the Prime Minister gave 26 to 31 May 2026 as holiday and the new date was 1 June 2026), citing Article 18 of the Civil and Commercial Procedures Law. Public holidays include Coptic Christmas (7 January), 25 January, Sinai Liberation Day (25 April), Labour Day (1 May), Sham El-Nessim (the Monday after Orthodox Easter), 30 June, 23 July, 6 October, the Islamic New Year, the Prophet's birthday, Eid al-Fitr and Eid al-Adha with Arafat Day. The Islamic dates follow the moon, and the Prime Minister often moves national holidays that fall early in the week to the Thursday and lengthens the Eid holidays by decree. The CbC report threshold is EGP 3bn of consolidated revenue for an Egyptian parent and EUR 750m for a foreign parent.