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ARTICLE · 05 DECEMBER 2018

Egypt New Updated Transfer Pricing (TP) Guidelines

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It is worth to be mentioned that it is not allowed not to follow the new transfer pricing guidelines unless it was requested by the taxpayer and accepted by the head of the ETA.

EgyptTax
Ahmed Ali
Ahmed Ali

Egyptian Ministry of finance has issued new decree 547 dated October 21, 2018 including the new updated transfer pricing guidelines which replaces the old guidelines issued in 2010.

The new guidelines will be the base for Egyptian Tax Authority (ETA) to rely when assessing the arm's length of financial or controlled commercial transactions which occur between associated enterprises (any person related to a taxpayer in a way that affects the determination of the tax base). These transactions can include, but not limited to:

  • Exchange of commodities or services.
  • Group cost allocation.
  • Royalties.
  • Interests.
  • Other financial or commercial activities.

It is worth to be mentioned that it is not allowed not to follow the new transfer pricing guidelines unless it was requested by the taxpayer and accepted by the head of the ETA.

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