When a company in Egypt needs tax advice: ten situations to check

Executive summary

• Documents requested in an examination are due within fifteen days of the request, extendable by an equal period, and notice that the examination has begun ends the right to file an amended return (Articles 41 and 33 of the Unified Tax Procedures Law 206 of 2020).
• An assessment may be contested within thirty days of learning of it; if it is not, it becomes final (Article 55).
• New applications to settle tax disputes may be filed until 31 December 2026 (Law 152 of 2026).
• An application to join the simplified tax regime cannot be withdrawn for five years from the day after it is filed (Article 5 of Law 6 of 2025).
• Interest, royalties and service fees paid to non-residents bear 20% tax with no deduction of costs, save for the exemptions in the article (Article 56 of Income Tax Law 91 of 2005).

Some tax situations are governed by a text that ties a right to a deadline, or makes a choice binding for years. Ten follow, each linked to the bulletin that covers it.

At set-up: the company form and the tax regime

The first decision at set-up is the company form, then the tax regime. Businesses whose annual turnover does not exceed EGP 20 million and which apply to benefit from Law 6 of 2025 are subject to it (Article 1), except for the cases excluded by Article 4. The decision should be studied before applying, because businesses subject to the law may not withdraw their application "before the lapse of five years starting from the day following the submission of the application" (Article 5). Details are in the simplified tax regime.

Examination, assessment and disputes

Examination notice. The tax office notifies the taxpayer of the examination date at least ten days in advance, subject to an exception set out in the article. The taxpayer must provide the data and copies of documents that the Egyptian Tax Authority (ETA) requests in writing within fifteen days of the request, extendable by an equal period on sufficient evidence of the difficulties faced (Article 41 of the Unified Tax Procedures Law). Once notified that the examination has begun, the taxpayer loses the right to file an amended return (Article 33). Details are in tax examinations in Egypt.

Assessment. The taxpayer may contest the assessment "within thirty days from the date of learning of it", and if the taxpayer does not contest the assessment form within the legal deadline, "the assessment becomes final" (Article 55). Cases listed in the same article, including service by posting or through the Public Prosecution, carry a different deadline. The stages are in appealing a tax assessment.

Pending dispute. Tax disputes pending or brought before the courts, the tax appeal committees, conciliation committees or grievance committees may be settled on application (Article 1 of Law 79 of 2016 as replaced by Law 14 of 2018). Law 152 of 2026 renewed that law, so the committees decide "the new applications submitted to them until 31 December 2026". Whether to apply or to continue should be weighed file by file; see tax dispute settlement.

Recurring deadlines and rates

Legal persons file their annual return "before the first of May of each year or within four months following the end of the financial year" (Article 31 of the Unified Tax Procedures Law), so a company's calendar should be built on its own financial year-end. The deadlines are gathered in the tax and insurance compliance calendar, and the rates in force, with their articles, in Egyptian tax rates for 2026.

Related parties and cross-border payments

Related parties. Where related persons set terms in their dealings that differ from those between unrelated persons and that reduce the tax base or shift the tax burden to an exempt or non-taxable person, the ETA "may determine the taxable profit on the basis of the arm's length price" (Article 30 of the Income Tax Law). A person whose total transactions with related persons during the tax period do not exceed EGP 30 million, the threshold in force since 18 December 2025, is exempt from the master file and the local file for transfer pricing (Article 12 of Law 206 of 2020 and Minister of Finance Decree 534 of 2025). The exemption is from those two files only, so in our reading it does not extend to disclosure in the return, and failure to disclose carries an amount equal to 1% of the transactions not declared (Article 13, last paragraph as replaced by Law 211 of 2020). Details are in transfer pricing in Egypt and the transfer pricing documentation threshold.

Payments to non-residents. Amounts paid to non-residents by sole proprietorships and legal persons resident in Egypt, and by non-resident entities with a permanent establishment in Egypt, for interest, royalties, services and the activity of a sportsperson or artist bear tax at 20% with no deduction of costs, subject to the exemptions in Article 56 of the Income Tax Law. The payer must withhold it and remit it "on the first working day following the day on which the tax was withheld" (last paragraph as replaced by Decree-Law 101 of 2012). Details are in tax on payments to non-residents.

A foreign company working in Egypt. A permanent establishment is "every fixed place of business through which all or part of the business of the enterprises of a person not resident in Egypt is carried on". It includes a building, construction, installation or assembly site, and the provision of services through employees or other individuals is treated as one, where either lasts "for a period or periods exceeding ninety days in total within any twelve-month period" (Article 4 of the Income Tax Law as replaced by Law 30 of 2023). The activity should also be tested against the applicable tax treaty, as explained in permanent establishment in Egypt.

New legislation

Laws 148 to 154 of 2026 were published in the Official Gazette, issue 30 bis (A), on 28 July 2026, each in force from the day after publication. They include a temporary rule in Article 4 of Law 151: taxes not yet final on the date the law took effect, owed by businesses and companies with annual turnover not exceeding EGP 10 million for tax periods beginning on 1 January 2023 and up to the end of the tax period before March 2025, are assessed at percentages of turnover or fixed annual amounts set in the article, and at no less than the taxes shown in their returns, without prejudice to the taxpayer's right to elect assessment under the Income Tax Law. The start year, 2023, is as corrected in the Official Gazette, issue 32 bis, of 8 August 2026; the text was first published with 2022. See the July 2026 tax package and the 2026 income tax amendments.

Item 2 of Article 22 of the Income Tax Law, as replaced by Law 30 of 2023, requires deductible costs to "be genuine and supported by electronic invoices or receipts as of July 2023 for electronic invoices and January 2025 for electronic receipts". The Minister may extend both deadlines by up to one year, and costs that custom does not evidence by documents, and those the Minister exempts, are excluded. In our reading of this text, outside the exceptions, the buyer's deduction depends on the electronic document its supplier issues. Details are in e-invoicing and the electronic receipt.

What this requires

• Record the date of each document request and the date each assessment became known: the documents deadline runs from the request, the appeal deadline from knowledge of the assessment.
• Review past returns before any examination.
• List pending disputes and decide on each before 31 December 2026.
• Measure related-party transactions for each tax period against the threshold in force, EGP 30 million since 18 December 2025.
• Check every payment to a non-resident against Article 56 before it is made.
• Compare the simplified regime and the temporary settlement with ordinary assessment before electing either.
• Make electronic invoices a contractual requirement for suppliers.

The firm's Tax Department reviews these situations before the decision is taken and prepares the reply, appeal or application each requires within its deadline.

Mahmoud Nassef, Founder Partner
Chartered Accountant, Ministry of Finance, Egypt

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.