Egypt tax examinations: stages, deadlines and taxpayer duties

Executive summary

• The basis is Chapters 2 (examination) and 3 (assessment notice), articles 41 to 44, of Part Five (Tax Oversight) of Unified Tax Procedures Law No. 206 of 2020, and its executive regulation, Ministerial Decision No. 286 of 2021.
• The taxpayer is notified of an examination at least ten days beforehand, and must produce the documents requested within fifteen days of the request, extendable for an equal period. Once notified that the examination has begun, the taxpayer can no longer file an amended return (article 33).
• The Authority may not assess or amend a tax after five years from the end of the legal filing deadline, under article 44 as replaced by Law No. 211 of 2020.
• The assessment notice is issued on the form the regulation prescribes for each tax and case, and must state the reasons for the adjustment.
• Enterprises under Law No. 6 of 2025 (annual turnover up to EGP 20 million) have their returns examined after five years from the date they applied to use it.

The examination notice and what the taxpayer must produce

The competent tax office must notify the taxpayer of the examination's date, place and estimated duration, on the prescribed form, at least ten days beforehand, by registered letter with acknowledgement of receipt, by electronic means with legal evidentiary value, or by other written means through which receipt is established (article 41). Notice that the examination has begun ends the taxpayer's right to file an amended return, as does the discovery of tax evasion (article 33).

A surprise examination is the exception, not the rule. It may proceed without notice where the Treasury's rights are at risk or evasion is suspected, with the approval of the Head of the Authority on a memorandum from the head of the tax office stating the reasons. Otherwise a field examination takes place only in the presence of the taxpayer or its legal representative, after notice of its date; if they do not attend despite notice, the Authority may proceed (article 10 of the regulation).

The taxpayer must provide the data and copies of documents and papers the Authority requests in writing, including customer and supplier lists, within fifteen days of the request. The Head of the Authority or a delegate may extend this for an equal period if the taxpayer gives sufficient evidence of difficulty. Meeting that deadline depends on the regular accounting books and records the taxpayer must keep, manually or electronically (article 38, first paragraph, as replaced by Law No. 150 of 2026).

Authority staff holding judicial-police-officer status may enter the taxpayer's premises during their working hours without prior notice; entry after working hours requires a permit issued by the head of their own work unit, and what is done or discovered is recorded in a report (article 42).

Burden of proof

The burden of proof lies on the Authority in two cases: when it corrects, amends or declines to rely on a return filed in accordance with the conditions and procedures the law lays down, and when it amends an assessment under the tax law (article 39). It lies on the taxpayer in three cases (article 40): an estimated assessment made because the data the taxpayer submitted, on which the assessment was based, proved inaccurate, or because the taxpayer did not submit the data the law requires, in the cases where the Authority may estimate; the taxpayer's own correction of an error in its return; and the taxpayer's challenge to the content of a report drawn up by an Authority officer with judicial-police status.

The assessment notice and its contents

The Authority notifies the taxpayer of an amended or estimated tax on the prescribed form, by registered letter with acknowledgement of receipt, by electronic means with legal evidentiary value, or by handing over the form at the workplace or tax office against a report signed by the taxpayer or its representative (article 43). The notice must state the reasons for correcting, amending or disregarding the return or for amending the assessment, and the tax office must set those reasons out in an approved memorandum with the supporting documents attached (article 48 of the regulation).

Where the Authority establishes revenue of which the taxpayer has not previously been notified, it assesses that revenue and notifies the adjustment on the form prepared for that case (article 43). Article 50 of the regulation names the forms: 19 (income tax), 19 (stamp duty), and 14 and 15 (VAT) for an amendment or estimate; and 19 bis (income tax), 19 bis (stamp duty) and 15 (VAT) for revenue not previously assessed. Its fourth paragraph was replaced by Ministerial Decision No. 42 of 2023.

When the Authority's right to assess lapses

Article 44 — replaced by Law No. 211 of 2020 within two months of the original law — reads:

"Without prejudice to article 74 bis of this law, the Authority may not, in any case, assess or amend a tax except within five years of the end of the period fixed by law for filing the return for the tax period."

The limitation period is interrupted by any ground provided in the Civil Code, by notice of the tax assessment, by a demand to pay, or by referral to the appeal committees.

The replacement removed the six-year period that the original 2020 text set for evasion cases. Article 74 bis, to which the article refers, was added by the same law and provides: "The limitation period of the criminal action for the offences set out in this law or the tax law begins to run after five years have elapsed from the end of the year in which the tax is due."

Neither Law No. 7 of 2025 nor Law No. 150 of 2026 touched articles 41 to 44. The first added article 45 bis (a cap on the delay charge or additional tax of 100% of the original tax) and articles 75 bis and 75 bis 1 (settlement); the second dealt with the first paragraph of article 38 and the temporary tax card (article 27 bis). Objection and appeal against an assessment have their own deadlines, outside the scope of this guide.

A special rule: enterprises under Law No. 6 of 2025

Law No. 6 of 2025 applies to enterprises with annual turnover not exceeding EGP 20 million that apply to benefit from it, including professional activities, whether or not they were registered for tax when it came into force (article 1), except the cases excluded by article 4, among them professional consultancy where at least 90% of annual turnover comes from advice to one or two persons. Article 12, last paragraph, provides:

"The tax returns of enterprises subject to this law shall be examined after five years have elapsed from the date of the application to benefit from its provisions, for income tax and value added tax."

The deferred examination period therefore runs from the date the application was filed, not from the date of tax registration or of the first return.

What this requires

• Review returns and file any amended return needed before an examination notice arrives: the right to do so ends with the notice.
• Log the date of each examination notice and each document request as soon as it arrives: the fifteen days run from the date of the request.
• Prepare customer and supplier lists and supporting documents before the Authority asks for them.
• Request an extension in writing, with sufficient evidence of difficulty, if fifteen days will not be enough.
• Track the five-year deadline for every open tax period, and log every notice or demand that interrupts it.
• Match an assessment notice to its tax type and case — an ordinary adjustment, or revenue not previously assessed — and check that it states its reasons before responding.
• Enterprises using Law No. 6 of 2025 should keep the application date on record: it starts the deferred examination.

The firm's Tax Department tracks examination notices, prepares the documents requested within their deadlines, and reviews assessment notices before they are answered.

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

Partner profile · Book a consultation

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.