Egypt's Law 151: settling non-final tax for firms up to EGP 10m
Is an Egyptian business assessed on turnover for 2023 and 2024? Yes, if turnover is up to EGP 10m and the tax is not final: never below its return, unless it elects ordinary rules.
Executive summary
- Under article 4 of Law No. 151 of 2026, the non-final taxes of businesses and companies whose annual turnover does not exceed EGP 10 million are assessed as a percentage of turnover or as a fixed annual amount. The article has applied since 29 July 2026.
- It covers tax periods from 1 January 2023 to the end of the tax period before March 2025; a corrigendum of 8 August 2026 replaced the year 2022 that appeared in the published text.
- The tax is EGP 1,000, 2,500 or 5,000 a year for turnover under EGP 1 million, and 0.5%, 0.75% or 1% of turnover from EGP 1 million up to EGP 10 million.
- The tax may not be lower than the tax shown in the return, and the taxpayer may elect assessment under the Income Tax Law.
- As at 9 October 2026 the Egyptian Tax Authority (the ETA) website carries no instructions, form or deadline for the article, but the ETA's circular on its examination plan to 30 June 2027 requires examiners to observe it.
The text as corrected
The law was published in the Official Gazette, issue 30 bis (A), on 28 July 2026 and applies from the day after publication (article 7); its other provisions are covered in Egypt income tax amendments 2026: what Law 151 changes. As corrected, article 4 reads (our translation):
"Non-final taxes due on the date this law comes into force shall be assessed on businesses and companies whose annual turnover does not exceed ten million pounds, for the tax periods beginning on 1 January 2023 until the end of the tax period before March 2025, in accordance with the following rules and at not less than the value of the taxes stated in the tax returns of these businesses and companies, all without prejudice to the taxpayer's right to elect to be assessed in accordance with the provisions of the Income Tax Law referred to."
The published text read "2022". The corrigendum in issue 32 bis of 8 August 2026 changed it to 2023.
Article 4 repeats the wording of article 3 of Law No. 30 of 2023, under which the non-final taxes of the same businesses due on 16 June 2023 were assessed "in accordance with articles (93 and 94)" of Law No. 152 of 2020, with the same floor and the same right of election. The difference is that article 4 sets its own periods and states the bands in its own text, Law No. 6 of 2025 having since repealed articles 93 and 94.
Scope: who and which periods
The business. The condition is annual turnover not exceeding EGP 10 million. The text does not restrict the article to any legal form, or to businesses previously assessed under Law No. 152 of 2020.
Non-final tax. Law No. 151 of 2026 does not define it; its text refers to the non-final taxes "due on the date this law comes into force", that is, 29 July 2026. A tax that became final before that date is outside the article.
The periods. Law No. 6 of 2025 came into force on 1 March 2025, the first day of the month after its publication on 12 February 2025. However the words "the end of the tax period before March 2025" are read, the 2023 and 2024 tax years of a business whose year ends on 31 December are within the article. The text does not expressly settle the 2025 period, which began before March and ended after it, or financial years that do not end on 31 December.
The tax and the floor
| Annual turnover | Tax |
|---|---|
| Under EGP 250,000 | EGP 1,000 a year |
| EGP 250,000 to under EGP 500,000 | EGP 2,500 a year |
| EGP 500,000 to under EGP 1 million | EGP 5,000 a year |
| EGP 1 million to under EGP 2 million | 0.5% of turnover |
| EGP 2 million to under EGP 3 million | 0.75% of turnover |
| EGP 3 million to EGP 10 million | 1% of turnover |
These are the bands of articles 93 and 94 of Law No. 152 of 2020. The percentage applies to the whole turnover: a business with turnover of EGP 6 million owes EGP 60,000 under the table.
The floor is the tax shown in the return. If the business in the example declared tax of EGP 80,000, it is assessed at that amount; if it declared EGP 45,000, it is assessed at the table amount. The article never reduces tax the taxpayer has declared, and it may raise the tax of a business that declared a loss or a small profit.
The right to elect ordinary assessment
The text preserves the taxpayer's right to be assessed under the Income Tax Law. The election is worth considering where the table produces more tax than a computation from regular books that will stand up to examination. The article does not say how or by when the election is made.
What the ETA has issued so far
The ETA issued Executive Instructions No. 95 of 2023 for the equivalent provision in article 3 of Law No. 30 of 2023, and as at 9 October 2026 has published no instructions, form or deadline for article 4 of Law No. 151 of 2026. Its lists of executive instructions and circulars contain none, and its page on the second package of tax facilitations carries only the texts of the laws.
Circular No. 4 of 2026 on the examination plan to 30 June 2027 requires examiners to "observe the implementation of the provisions of the second package of tax facilitations, in particular Law No. 151 of 2026 (article 4)". The plan covers returns not supported by regular accounts, and cases where returns were not filed or were filed late, up to the 2025 period.
Relation to Law 6 of 2025 and Law 152 of 2026
Law No. 6 of 2025. Its article 15 repealed articles 93 and 94 of Law No. 152 of 2020, among others. Since 1 March 2025 it has governed businesses with annual turnover not exceeding EGP 20 million that apply to benefit from it, at its own rates, set out in Egypt's Simplified Tax Regime for Small Enterprises: Full Guide. Article 4's cut-off, "before March 2025", falls where that law begins.
Law No. 152 of 2026. It renewed until 31 December 2026 Law No. 79 of 2016 on ending tax disputes, which covers disputes pending or brought before the courts at every level, the tax appeal committees and the conciliation or grievance committees. The request is made on the form attached to Minister of Finance Decree No. 450 of 2026 and may be filed free of charge on the ETA's electronic portal. The two routes differ: article 4 sets the amount of tax, while the dispute law is a procedure for ending a pending dispute. The details are in Egypt tax dispute settlement extended to 31 December 2026.
What this requires
- Establish turnover for 2023 and 2024 and the band for each year, and keep the documents that support it, since turnover is the tax base.
- Compare the table tax, year by year, with the tax in the return and with tax computed under the Income Tax Law.
- Record where each period stands on examination and appeal: the article does not reach a tax that became final before 29 July 2026.
- Identify any year in which ordinary assessment favours the business, and be ready to elect it once the way of electing is settled.
- Where the financial year does not end on 31 December, do not assume a given period is covered until the ETA issues instructions.
- Where a dispute is pending for the same periods, work out the effect of article 4 before requesting that it be ended; new requests may be filed until 31 December 2026.
The firm's Tax Department computes the article 4 tax for each year, compares it with the return and with ordinary assessment, prepares the election of ordinary assessment where it favours the business, and follows the instructions the ETA issues on the article.
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.