Transfer pricing in Egypt

Transfer pricing in Egypt at a glance

Regulation Type National regulations with reference to the OECD
Are there specific transfer pricing regulations? Yes
Submission deadline Contemporaneously
Submission deadline upon request N/A
Annual update required N/A
Official language requirements Arabic (English mostly accepted)
Potential impact of penalties N/A

 

Egyptian tax law

Rules for transfer pricing in Egypt are based upon:

  • Income Tax Law No. 30 and 91
  • Executive regulation Articles No. 38, 39 and 40

OECD

Rules for transfer pricing in Egypt do not follow the OECD Transfer Pricing Guidelines as such. However, if the national regulations are not applicable in order to ensure an arm’s length price, the Income Tax Law states that the OECD Guidelines may be used.

Methods

Accepted methods

Accepted methods are:

  • the comparable uncontrolled price method
  • the resale price method
  • the cost plus method

Priority of methods

The transfer pricing regulations in Egypt only prescribe the above-mentioned methods and these methods are always preferred. Only when these methods are not applicable, a taxpayer can choose other methods.

Documentation requirements

Information that should be included in the documentation:

  • The name of the related party
  • Nature of the transactions
  • Amount of transactions
  • The transfer pricing method used

Language

Rules for transfer pricing in Egypt prescribe that all documentation should be submitted in Arabic. However, English is mostly accepted.

Requirements to prepare documentation annually

Rules for transfer pricing in Egypt prescribe that documentation should be updated annually since documentation is required contemporaneously with the filling of the tax return.

Submission deadline upon request by tax authorities

Not applicable.

Advance Pricing Agreements

General

Rules for transfer pricing in Egypt officially provide for the option to obtain an Advance Pricing Agreements (APA). However, up to now none have been concluded so it is assumed that in practice it is not possible to obtain APA’s.

Terms

Transfer pricing regulation do not provide for any information with regard to the terms for which an APA can be agreed upon.

Penalties

In Egypt there are no specific transfer pricing penalties, meaning that ordinary penalties apply.

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