Transfer pricing has become one of the key areas of tax audits in Egypt as the Egyptian Tax Authority (“ETA”) continues aligning the Egyptian tax framework with OECD standards and international tax transparency requirements. In recent years, the ETA has intensified its examination of related-party transactions, particularly within multinational groups, making transfer pricing compliance an essential component of corporate tax risk management.
The Egyptian transfer pricing regime is governed by Article 30 of the Egyptian Income Tax Law No. 91 of 2005, the Executive Regulations, the Egyptian Transfer Pricing Guidelines (“ETPG”), as well as the relevant ministerial decrees and administrative instructions. Under these rules, companies engaging in related-party transactions are required to maintain contemporaneous documentation demonstrating that such transactions comply with the arm’s length principle, whether for domestic or cross-border transactions.
