Egypt tax dispute settlement extended to 31 December 2026

The tax dispute settlement committees continue to hear taxpayers' applications not yet decided, and will decide new applications submitted to them up to 31 December 2026. Law 152 of 2026, published in the Official Gazette, issue 30 bis (A), on 28 July 2026 and in force from the following day, renews the provisions and procedures of Law 79 of 2016 on the settlement of tax disputes (Official Gazette, issue 38 bis (C), 26 September 2016) until that date. The renewal does not extend to Law 5 of 2025 on settling the position of certain taxpayers (Official Gazette, issue 6 bis (F), 12 February 2025), whose window closed on 12 August 2025. Law 152 is one of seven laws published in the same issue, all reviewed together in Egypt's July 2026 tax package.

The renewal concerns taxpayers in dispute with the Egyptian Tax Authority (the ETA) or the Real Estate Tax Authority before the courts or the appeal, conciliation or grievance committees. To end such a dispute before the settlement committees, a taxpayer must file an application on the prescribed form no later than 31 December 2026.

The settlement mechanism

Law 79 provides an exceptional route for resolving tax disputes outside the courts. It covers disputes pending, or brought, before the courts at every level, the tax appeal committees, the conciliation committees and the grievance committees, between the ETA or the Real Estate Tax Authority and taxpayers, where the dispute arises under the tax laws the two authorities administer, whatever stage the case or appeal has reached (article 1 of Law 79, as substituted by article 2 of Law 14 of 2018, published in the Official Gazette, issue 8 bis (E), 27 February 2018).

Applications are decided by committees formed by decree of the Minister of Finance. Each is chaired by a specialist from outside the competent authority and includes a member of the judiciary of at least counsellor rank and a technical member from that authority's staff (article 2 of Law 79, as amended by Laws 14 and 174 of 2018).

The taxpayer files the application with the competent authority on the prescribed form, stating the subject of the dispute, the number of the case or appeal and the grounds, with copies of the supporting documents (article 3 of Law 79). The form is set by Minister of Finance Decree 450 of 2026, issued on 16 August 2026. Under it, the application goes to the ETA, or to the Real Estate Tax Authority as the case may be, on the annexed form, and may be filed free of charge through the competent authority's electronic portal (article 1 of Decree 450).

If the committee considers the application serious, the court or committee hearing the dispute is notified, and proceedings are suspended by operation of law for three months. The suspension renews automatically for a further three months unless the competent authority notifies the court or committee that no settlement has been reached (article 4 of Law 79). The committee issues a recommendation in the light of established legal principles and the circumstances of the case. If the taxpayer accepts it in writing within five days of its being presented, and the minutes are approved by the Minister of Finance or the Minister's delegate, the minutes have the force of an enforceable instrument and the dispute is deemed settled by operation of law. If the recommendation is rejected, or the suspension expires without a settlement, the proceedings resume by operation of law (article 5 of Law 79).

Scope of the renewal and the deadline

The second paragraph of article 1 of Law 152 provides (unofficial translation):

The committees formed under the provisions of Law No. 79 of 2016 shall continue to hear applications not yet decided, and shall decide new applications submitted to them up to 31 December 2026.

Law 152 makes no change to the mechanism or to the conditions for admitting an application. It has two articles: the renewal itself, and publication and entry into force.

The deadline is firm. The committees have no jurisdiction over new applications submitted after 31 December 2026, and the dispute then continues before the body hearing it. The same date ends the renewal as a whole (the first paragraph of article 1 of Law 152), and we have found no provision in Law 152 or Law 79 under which the committees continue after that date to decide an application submitted before it but not yet decided.

Law 79 is temporary by its own terms: article 8 gave it a life of one year from the day after its publication, and it has continued only through successive renewal laws. It was amended by Laws 14 and 174 of 2018, and renewed by Laws 16 and 173 of 2020, 153 of 2022, 160 of 2024 and now 152. A further renewal should not be assumed.

Distinction from Law 5 of 2025

The two laws are frequently confused, and the difference is material.

A taxpayer who missed the Law 5 of 2025 window cannot now obtain its terms, and a settlement under Law 79 rests on the committee's recommendation in each file rather than on a fixed rate.

The late payment charge during a dispute

For income tax, the late payment charge is due on unpaid tax above EGP 200, from the day after the filing deadline (article 110 of the Income Tax Law issued by Law 91 of 2005). It is not suspended by an objection or an appeal, nor by the suspension of proceedings that follows a settlement application. If the dispute ends with all or part of the tax upheld, the charge is due on that amount.

It is computed at the Central Bank of Egypt credit and discount rate announced on the 1 January preceding the day it starts, plus 2%, disregarding fractions of a month and of a pound. Under Circular 1 of 2026 issued by the Head of the ETA, that rate was 20.50% on 1 January 2026, so a charge starting in 2026 runs at 22.50% a year: EGP 112,500 a year on tax of EGP 500,000.

The charge may not exceed 100% of the principal tax on which it is due (article 45 bis, added by Law 7 of 2025 to the Unified Tax Procedures Law issued by Law 206 of 2020). In addition, 30% of it is waived on tax that becomes due under an agreement with the ETA reached before the appeal committee decides, provided the taxpayer pays the tax due (article 110 of Law 91, as amended by Law 16 of 2020).

What we recommend

• Schedule all live tax disputes, showing the amounts, the tax periods, the body hearing each dispute and the stage it has reached.
• Estimate the likely cost of settlement against the probable outcome of the dispute plus the late payment charge accrued to the expected date of determination.
• Decide on each file separately whether to apply for settlement or continue the litigation.
• Assemble the supporting documents (the audit file, correspondence, appeal committee decisions and evidence of payment) so that the application can be filed well before the deadline.
• Keep other live deadlines in view, in particular the sixty days from the day following notification within which an appeal committee decision may be challenged before the Administrative Court (article 65 of Law 206).

Preparing an application and its supporting documents takes time, so files are better reviewed now. The firm's Tax Department reviews live disputes and prepares and pursues settlement applications.

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.