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Transfer pricing has evolved into a central issue in international taxation, corporate governance, and value creation for multinational enterprises.

Transfer Pricing is that basis used by the Tax authority to determine the price to be used when determining the taxable profit among non-related parties,

Valuation is a complex discipline that often involves navigating diverse legal, regulatory, and cultural landscapes across multiple jurisdictions. Valuation professionals face unique challenges...

In recent years, tax administrations in many countries around the world have turned to the implementation of the e-invoice system as part of their digital transformation plans, with the aim of developing tax...

While these advances offer unprecedented efficiency and innovation, they introduce complex challenges for transfer pricing. Traditional frameworks assume that IP is created and owned by humans, but AI-generated IP blurs these assumptions, raising critical questions about valuation, ownership, risk allocation, and regulatory compliance.

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.

The oil and gas sector play a vital role in the Egyptian economy, contributing significantly to national income and attracting foreign investment...

Many multinational groups rely on Egyptian entities for R&D operations, engineering, software development, product testing, technical support, manufacturing improvements, and regional innovation functions. These activities often generate substantial commercial value and may contribute directly to the development or enhancement of intellectual property owned within the wider group.

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.

In today's global business arena, innovation is king — and at the heart of that innovation lies research and development (R&D).

In multinational enterprises (MNEs), intergroup financial transactions play a crucial role in optimizing capital allocation, liquidity management, and tax efficiency.

Transfer Pricing Policy Below Threshold in Egypt ensures arm’s length compliance even when transactions fall below documentation thresholds.

In recent years, there has been a notable surge in the Egyptian Tax Authority's (ETA) focus on the tax treatment of cross-border payments, particularly regarding withholding tax (WHT) on service payments to non-residents.

Holding companies in Egypt play a vital role in structuring tax frameworks for tax groups, especially those with substantial tremendous value.

In recent years, the world has witnessed a tremendous development in artificial intelligence technologies, so that it is no longer just a technical tool used to improve some processes within companies, but has become a key element in creating economic value and generating revenue.

Changes in business models and supply chains have become increasingly common as multinational groups respond to cost pressures, digitalization, geopolitical developments, market expansion, and the need for greater supply-chain resilience. While these changes are usually driven by commercial considerations, they can significantly affect a group’s transfer pricing position.

Egyptian Tax Authority (ETA) has released recently its practical manual for Country by Country Reporting (CbCR) as outlined in Decree No. 221/2018 and No. 547/2018 which amends the Egyptian Transfer Pricing guidelines.