Egypt's tax examination plan to 30 June 2027: files covered and rules

Under its examination plan to 30 June 2027, the Egyptian Tax Authority (the ETA) examines the payroll and stamp duty files of all businesses in full, outside the sample system, completes the examination of earlier samples without going beyond them, and may not set aside accounting books and approved computerised systems during an examination unless material evidence proves that they are not reliable and regular. The plan was issued in 2026 as Periodic Book No. 4 of 2026, signed by the head of the ETA, and the book presents itself as building on what was achieved under Periodic Book No. 8 of 2024, the examination plan for 1 July 2024 to 30 June 2025. The book also lists other returns and cases the plan covers, some of them up to the 2025 period.

The book is addressed to the ETA's tax centres, tax offices and examiners, not to taxpayers. It still matters to every business in two ways: it sets out the returns and cases the ETA aims to finish examining, and it states what an examiner must observe in dealing with a business's books and in estimating its profits.

Samples and full examination

The first item in the plan is completing the examination of earlier samples under the ministerial decrees issued for that purpose. Tax offices must not go beyond what the samples for earlier years contain, and must not examine tax periods that do not appear in the sample lists. The book gives its reason, in words we quote here, as elsewhere in this article, in unofficial translation: to avoid the problems raised on this point "so that examination procedures are not exposed to nullity". Where a file moves between tax offices and centres under the ETA's merger plan, the sample years it had at the office or centre it came from are observed.

Two kinds of file are taken out of the sample: payroll files (wages, salaries and similar payments) and stamp duty files. In the book's words, the sample system "does not apply to them, and they are examined in full". All centres and offices are to finish examining them quickly, up to the latest tax period. Priority goes to examining the wages and salaries base of files that are in the examination sample, and also of high-yield or labour-intensive files.

The plan extends from sample files to the files of sister and related companies and to changes of legal form, "where their link to the sample files is established", in coordination with the other tax office if the file sits there. Tax evasion cases, and mergers, divisions and acquisitions, form a separate item of the plan that carries no such condition.

Other returns and cases in the plan

Alongside the samples, the plan covers:

• returns for commercial, industrial, professional and non-commercial activities and for real estate wealth that are not supported by regular accounts, up to the 2025 period;
• cases where tax returns were not filed, and returns filed after the legal deadline, up to the 2025 period;
• amended returns for earlier periods filed after the deadline for the return, which are based on regular books and accounts;
• returns for 2023, 2024 and 2025 supported by documents that the taxpayer asks to have examined, once the request has been put to the Examination Sector and approved;
• urgent cases, including cessation, departure, assignment of all or part of the activity, change of legal entity, refunds and bankruptcy, in which centres and offices continue to complete examination, assessment and collection;
• files with re-examination decisions, and real estate disposal files under article 42 of the Income Tax Law issued by Law No. 91 of 2005;
• files of businesses leased for a fixed term under Law No. 4 of 1996, up to the end of the lease, car files, and files of newspapers, magazines and publications holding foreign licences that obtained permits to print and distribute in Egypt for set periods.

Books and estimation during examination

The second part of the book sets what must be observed while an examination is carried out. A taxpayer's regular books and records may not be disregarded or set aside unless the ETA proves them incorrect by documents it produces. The book returns to the point in a further item that adds computerised systems:

"Accounting books and approved computerised systems are not to be set aside unless it is proved by material evidence that they are not reliable and regular. The head of the centre or office is to verify that the reasons for setting aside those books and systems are serious, and to give the necessary direction so that disputes arising from setting them aside are ended quickly."

On estimation, the book requires objectivity and no exaggeration in estimating profits, because estimation "is not an absolute power of the tax office but must be based on objective grounds and evidence". The burden of proof and the stages and deadlines of an examination under the Unified Tax Procedures Law issued by Law No. 206 of 2020 are explained in Egypt tax examinations, and the books a taxpayer must keep in Egypt's Mandatory Commercial Books and Electronic Bookkeeping.

Examiners also check that taxpayers who must withhold or collect tax on account and make advance payments apply the tax law and Law 206, with their implementing regulations, correctly; that they complete the statutory forms accurately; and that they pay the ETA on time. Non-compliant companies and bodies are reported to the Central Administration for Collection Programmes and Revenues, and the measures the law provides are taken against them. Withholding and its form are covered in Withholding tax in Egypt.

Priority in examination goes to important files, high-yield files and urgent cases, and to requests for settlement of appeals under article 66 of Law 206. A taxpayer with a pending dispute has a further route: a request under Law No. 79 of 2016 on ending tax disputes, whose committees decide new requests filed with them until 31 December 2026 (article 1 of Law No. 152 of 2026). The details are in Egypt tax dispute settlement extended to 31 December 2026.

The tax facilitation packages

The book asks examiners to observe the second package of tax facilitations, in particular article 4 of Law No. 151 of 2026 amending certain provisions of the Income Tax Law. That article sets rules for assessing the non-final taxes of businesses and companies whose annual turnover does not exceed EGP 10 million; its scope and bands are covered in Egypt's Law 151: settling non-final tax for firms up to EGP 10m.

It also asks them to observe Executive Instructions No. 95 of 2023 on applying article 3 of Law No. 30 of 2023, "without prejudice to the taxpayer's right to request assessment under Law No. 91 of 2005 as amended", and Instructions No. 17 and No. 25 of 2025 on the controls for applying the laws of the first package of tax facilitations.

What to review before an examination notice

• Where each period up to 2025 stands against the plan: a return not filed or filed late, not supported by regular accounts, or amended after the deadline, checking also whether the period appeared in an earlier sample list.
• The payroll and stamp duty files up to the latest tax period.
• Withholding, collection on account and advance payment forms, and the dates they were paid.
• The regularity of the books, records and computerised system and their supporting documents. If the books are set aside, we recommend asking for the material evidence relied on and raising the matter with the head of the centre or office.
• A request to examine returns for 2023 to 2025 supported by documents, if the business wishes, which requires the Examination Sector's approval. A business planning to cease activity, change its legal entity or claim a refund is an urgent case under the plan.

The firm's Tax Department reviews where a business's files stand against the examination plan and represents it before the tax office during the examination.

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.