Egypt temporary tax card: eight months, no electronic invoice

The Egyptian Tax Authority (the ETA) may, on the taxpayer's application, grant a temporary tax card for eight months to complete the incorporation and licensing of the taxpayer's activity, and the card may not be used to issue electronic receipts or invoices. This is article 27 bis, added by Law 150 of 2026 amending certain provisions of the Unified Tax Procedures Law issued by Law 206 of 2020; Law 150 was published in the Official Gazette, issue 30 bis (A), on 28 July 2026 and applies from the day following its publication. It is one of seven laws published in the same issue of the Official Gazette; all seven are reviewed together in Egypt's July 2026 tax package.

Law 150 also replaced the first paragraph of article 38, so that the duty of every taxpayer carrying on a commercial, industrial, craft or professional activity to keep regular accounting records and books no longer depends on annual turnover exceeding EGP 500,000.

The temporary tax card

Article 2 of Law 150 added a new article 27 bis, which reads, as corrected by the notice published in the Official Gazette, issue 32 bis, on 8 August 2026 (unofficial translation):

"By exception from article 27 of this Law, the ETA may, on the taxpayer's application, grant a temporary tax card valid for eight months for the purposes of completing the incorporation and licensing of its activity. Where any amounts are due to the ETA during the validity of the temporary tax card, the taxpayer shall settle them starting from the date of its expiry. The Head of the ETA shall issue a decision setting the form of the temporary tax card, specifying the data to be entered on it, its validity date, and the procedures governing it in a manner not conflicting with the ETA's electronic systems.

Without prejudice to the first paragraph of this article, the temporary tax card may not be used to issue electronic receipts or invoices."

Three points in that text deserve attention.

The grant is discretionary, not automatic. The text says the ETA "may", whereas article 27 provides that the competent tax office "shall issue a tax card to the registered taxpayer". The temporary card is therefore not a right that follows from asking.

The purpose is defined. The card is granted "for the purposes of completing the incorporation and licensing of its activity", and the text does not list carrying on the activity among those purposes.

Amounts due are deferred, not extinguished. What falls due to the ETA during the card's validity must be settled starting from the date it expires. The card creates no exemption; it moves the date of payment.

The electronic invoicing restriction

The text bars the use of the temporary card to issue electronic receipts or invoices, so in practice the card does not enable a business to carry on any activity that requires the issue of an electronic invoice or receipt.

A business that must issue electronic invoices or receipts from the start of its activity gains nothing operational from the card. Its use is confined to completing the formalities that themselves require a valid tax card. Whether to apply for one depends on whether the activity will need electronic invoicing during those eight months.

Regular books without the turnover condition

Article 1 of Law 150 replaced the first paragraph of article 38 with the following (unofficial translation):

"Without prejudice to the provisions of Law No. 6 of 2025 on certain tax incentives and facilities for projects whose annual turnover does not exceed twenty million pounds, and having regard to the provisions of the Law on Joint Stock Companies, Partnerships Limited by Shares, Limited Liability Companies and Single Person Companies issued by Law No. 159 of 1981, every taxpayer carrying on a commercial, industrial, craft or professional activity shall keep the regular accounting records and books provided for in the Commerce Law issued by Law No. 17 of 1999, manually or electronically."

The change is twofold. First, it deletes the condition "if its annual turnover exceeds five hundred thousand pounds", which limited the duty in the 2020 text, so the duty now applies whatever the turnover. Second, it opens with "without prejudice to" Law 6, so projects subject to that law remain under its rules, including their exemption from keeping the records, books and documents provided for in Law 206, while they must follow the simplified systems for records, books and documents that a decision of the Minister of Finance sets (article 13 of Law 6), set out in Egypt's Simplified Tax Regime for Small Enterprises.

Keeping the books "manually or electronically", and the references to the Commerce Law and the Companies Law, were already in the original text of article 38. The detail is in Egypt's Mandatory Commercial Books and Electronic Bookkeeping.

What we recommend

• For businesses being incorporated: assess the need for a temporary card against the electronic invoicing restriction before applying.
• For those holding one: schedule the amounts falling due to the ETA during its validity, and record the expiry date as the start of the payment period.
• For taxpayers whose turnover did not exceed EGP 500,000: keep regular books under Commerce Law 17 of 1999 from Law 150's entry into force, unless they are projects subject to Law 6 of 2025.

The firm's Tax Department advises businesses being incorporated on their position and tracks the implementing decisions as they are issued.

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.