Appealing a tax assessment in Egypt: from committee to court
What is the deadline to contest an Egyptian tax assessment? Thirty days from learning of it, or it becomes final; then two committees and sixty days to go to court.
Executive summary
- The deadline to contest a tax assessment form is thirty days from the date the taxpayer learned of it; otherwise the assessment becomes final (article 55).
- The objection first goes to an internal committee, which decides within sixty days of receiving the file, extendable once for the same period (article 56).
- If it does not decide in time, the file is referred to the Appeal Committee; if it decides but does not refer the dispute within thirty days, the taxpayer may put the matter in writing to the Appeal Committee's chair within fifteen days (article 56).
- The Appeal Committee decides within sixty days, extendable once (article 61), and the tax is payable on its decision even if that decision is challenged before the Administrative Judiciary Court within sixty days of the day after notification (articles 64 and 65).
- A final assessment can be corrected on request within five years, in the cases listed in article 67.
The tax examination ends when the taxpayer is notified of the tax assessment form. This bulletin follows the route for contesting that assessment under the Unified Tax Procedures Law, Law 206 of 2020, and its Executive Regulations, issued by Minister of Finance Decree 286 of 2021. Article numbers refer to the Law unless the Regulations are named.
The deadline, and when an assessment becomes final
An assessment is notified by registered letter with acknowledgement of receipt, by any electronic means with legal evidentiary force, or by delivery against a record signed by the taxpayer or their representative (article 54). The taxpayer may "object to that assessment within thirty days from the date they learned of it"; if no objection is made "within the legally prescribed period, the assessment becomes final" (article 55).
Where notice was given by posting because the premises were closed or the taxpayer was absent or refused delivery, or was served through the Public Prosecution, or where the acknowledgement of receipt lacks the particulars required by the general postal instructions, the taxpayer may challenge the assessment or the Appeal Committee's decision within sixty days of the date of the seizure imposed on them (article 55), meaning the date they learned of the seizure (Regulations, article 60).
The internal committee
The objection is made by a memorandum in one original and three copies, lodged with the competent tax office, which returns one copy to the taxpayer marked with the filing date (Regulations, article 61). The memorandum must set out every point of disagreement precisely, with its substantive grounds; "an objection that does not contain the disputed points shall not be considered" (article 56). It is heard by an internal committee chaired by an official of at least director-general grade, with two Authority officials holding judicial police status, none of whom may have examined or reviewed the matter before (article 58).
The committee sets a hearing within thirty days of filing, the tax office sends it the file within fifteen days at most, and the committee then decides within sixty days of receiving the file, extendable once for the same period for serious reasons (article 56). The taxpayer is entitled to a copy of the hearing minutes on signing them (article 60). A taxpayer who does not attend is notified once more, and if they still do not attend the committee refers the dispute to the Appeal Committee (article 59).
If the disagreement is settled, "the tax becomes final" and the tax office assesses it on the basis of the committee's decision. Otherwise the committee refers the dispute to the Appeal Committee, with its opinion, within thirty days of deciding; if it does not, the taxpayer may put the matter in writing to the Appeal Committee's chair, attaching a copy of the objection memorandum, within fifteen days, and the chair must set a hearing within fifteen days. If the decision deadline passes without a decision, the file is referred to the Appeal Committee (article 56).
The Appeal Committee
Appeal committees are formed by decree of the Minister of Finance, chaired by a member of a judicial body, with two Authority officials and two tax experts, one nominated by the Federation of Chambers of Commerce or the Federation of Industries and the other by the Syndicate of Commercial Professions. They are permanent and report administratively to the Minister directly (article 61), and they decide only the points of disagreement set out in the objection memorandum (article 62).
The committee gives both parties at least ten days' notice of the hearing; if the taxpayer or their representative does not attend, it decides on the documents submitted (article 62), and the taxpayer may instead send memoranda and documents through the tax office (Regulations, article 64). It must decide within sixty days of the file being lodged with it or of a hearing being set, whichever is later, extendable once for serious reasons, and its decision must be reasoned and unconditional, stating the tax due and the basis of its calculation (article 61).
The decision is taken by majority, within the limits of the Authority's estimate and the taxpayer's requests, and is signed by the chair and the secretary within a week at most; the assessment is amended accordingly, and tax not yet collected is collected under the decision. "The tax shall be payable on the basis of the committee's decision, and a challenge to its decision before the competent court shall not prevent collection of the tax or the taking of administrative seizure measures to recover it" (article 64).
Before the appeal is reserved for decision, the taxpayer may ask the tax office to settle the points of disagreement, attaching a certificate from the Appeal Committee that the appeal has not been reserved for decision (Regulations, article 66). The committee suspends its review and the tax office decides on the request within thirty days of filing; an agreement is recorded in minutes signed by both parties that stand as an enforceable instrument (article 66), and otherwise the appeal resumes (Regulations, article 66).
Before the Administrative Judiciary Court
Either the Authority or the taxpayer may challenge the Appeal Committee's decision before the competent Administrative Judiciary Court within sixty days of the day following notification of the decision. As an exception to the Council of State Law, Law 47 of 1972, these cases are decided without referral to the State Commissioners Authority, may be heard in closed session, and judgment is "always given on an expedited basis" (article 65).
Settlement under Law 79 of 2016 also remains available for disputes pending before the appeal committees and the courts: Law 152 of 2026 renewed its provisions until 31 December 2026, and the settlement committees will decide new applications submitted to them up to that date, as covered in tax dispute settlement to 31 December 2026.
Key deadlines
| Stage | Deadline | Basis |
|---|---|---|
| Objecting to the assessment form | 30 days from learning of it | Article 55 |
| Objecting after notice by posting, through the Public Prosecution or with a defective acknowledgement of receipt | 60 days from learning of the seizure | Article 55; Regulations, article 60 |
| Internal committee hearing | 30 days from filing | Article 56 |
| Internal committee decision | 60 days from receiving the file, extendable once | Article 56 |
| Referral to the Appeal Committee | 30 days from the decision | Article 56 |
| Taxpayer raises the matter with the Appeal Committee's chair | 15 days after the referral period lapses | Article 56 |
| Appeal Committee decision | 60 days from lodging of the file or the setting of a hearing, whichever is later, extendable once | Article 61 |
| Settlement request | Before the appeal is reserved for decision; the tax office decides within 30 days of filing | Article 66 |
| Challenge before the Administrative Judiciary Court | 60 days from the day after notification of the decision | Article 65 |
| Request to correct a final assessment | 5 years from finality | Article 67 |
Correcting an assessment after it becomes final
The Authority must correct a final assessment resting on the tax office's estimate or amendment or on an Appeal Committee decision, on a request filed within five years of the date it became final, in the cases listed in article 67. They include: the taxpayer never carried on the activity assessed; tax assessed on an exempt activity or on revenue not subject to it; an error in the rate or type of tax; the same tax assessed on the same revenue more than once; and, generally, the taxpayer obtaining conclusive documents showing the assessment to be wrong. The request goes to a committee that includes a member of the Council of State, which decides within sixty days at most of receiving the file (Regulations, article 67); its decision takes effect only once approved by the Head of the Authority (article 67). Because this route is limited to those cases, it is no substitute for objecting in time.
What this requires
- Record the date the assessment form was received as soon as it arrives: the thirty days run from then, not from the internal review of the figures.
- State every point of disagreement and its substantive grounds in the objection memorandum, and keep the copy marked with the filing date: the Appeal Committee considers only the points set out in it.
- Attend the internal committee's hearings and ask for a copy of the minutes; if thirty days pass after its decision without referral, put the matter in writing to the Appeal Committee's chair within fifteen days.
- Consider a settlement request before the appeal is reserved for decision.
- Count the court deadline from the day after notification of the Appeal Committee's decision, not from the date it was issued.
- Arrange payment as soon as the Appeal Committee decides: a court challenge does not stop collection.
The firm's Tax Department prepares objection memoranda and tracks their deadlines before both committees and the Administrative Judiciary Court.
Mahmoud Nassef — Chartered Accountant (Egyptian Register), Founder Partner
Member, Egyptian Society of Accountants & Auditors
Member, Egyptian Tax Society
Member, Egyptian Society for Public Finance and Taxation
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Disclaimer: This bulletin is prepared for general information on the legislation in force at the date of its publication. It does not constitute a professional opinion or tax or legal advice on any particular matter, and it should not be relied upon in place of advice based on an examination of the circumstances of each case. Nassef & Partners International accepts no responsibility for any action taken, or refrained from, in reliance on its contents. The positions stated remain subject to subsequent legislation and decisions.