Transfer Pricing Challenges And Solutions In Egypt

Transfer pricing challenges have become one of the most significant and pressing issues in modern tax administration. It is no longer perceived as a purely technical accounting matter but rather as an issue that touches the very core of state sovereignty over public revenues and the equitable distribution of the tax burden among taxpayers. The growing role of multinational enterprises and the expansion of cross-border intra-group transactions have made transfer pricing a central focus of tax policy.

Any deviation in the pricing of related-party transactions is now seen as a potential avenue for profit shifting and base erosion. International Framework At the international level, the OECD Transfer Pricing Guidelines have established the most widely accepted reference framework, centered on the Arm's Length Principle. This principle, enshrined in Article 9 of the OECD Model Tax Convention, requires that transactions between related parties be priced under the same