Navigate the complex TP regulations in Egypt. Ensure alignment with the Unified Tax Law and fulfill mandatory reporting requirements for Local and Master files.
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Transfer Pricing in Egypt has undergone significant reform following the issuance of the Unified Tax Law No. 206 of 2020. The Egyptian Tax Authority (ETA) strictly enforces the Arm’s Length Principle for all transactions between related parties.
Egypt’s regulations are closely aligned with OECD guidelines, requiring multi-layered documentation and electronic filing via the dedicated tax portal to ensure transparency and compliance with international BEPS standards.
Introduced a formalized documentation structure and established stiff penalties for non-compliance or delayed filings.
Empowers the ETA to adjust the value of transactions between related parties if they do not reflect market value.
Provides the foundational administrative guidance on how the ETA interprets and applies OECD-based TP methods.
Global group overview for taxpayers with transactions over EGP 8 Million.
Taxpayers with related party transactions exceeding EGP 8 million per year must prepare a Master File.
This should be prepared in accordance with the group's ultimate parent filing deadline and made available to the ETA upon request.
Entity-specific analysis due within 2 months of tax return filing.
The Local File is mandatory for entities with related party transactions exceeding EGP 8 million.
It must be submitted electronically within 60 days following the submission of the annual corporate income tax return to avoid substantial penalties.
Reporting for MNEs with revenue over EGP 3 Billion.
For Egypt-parented MNEs, the threshold for CbCR is a consolidated group revenue of EGP 3 billion.
For subsidiaries of foreign-parented groups, the global threshold of EUR 750 million applies for notification and reporting purposes.
Preparation and filing through the ETA E-Portal.
Benchmarking using Egyptian and MENA-region databases.
Negotiating Advance Pricing Agreements with the ETA.
Strategic defense and technical support during tax inspections.
Our Cairo-focused experts help you mitigate risks and ensure 100% compliance with Unified Tax Law requirements.
Contact Egypt TeamFor further information on transfer pricing please contact:
Leader - Gulf Practice
Leader - Global TP
Leader - TP Policy
TP Specialist – Gulf Region