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Criteria for Determining Related Persons Under Egypt’s Tax Regulations

The Related Persons Under Egypt’s Tax booklet provides an essential guide on the Egyptian income tax regulations concerning “related persons”—entities with close economic or familial connections. These relationships can affect the accuracy of reported taxable income, necessitating specific tax compliance measures.

Key Topics Include:

  1. 1. Definition of Related Persons: Criteria such as direct control, common ownership, family ties, and economic dependence establish related-person status, impacting tax obligations.
  1. 2. Tax Compliance for Related Persons in Egypt: Egyptian tax law enforces the arm’s-length principle, requiring fair market conditions in transactions. Compliance mandates include transfer pricing documentation and adherence to thin capitalization rules.
  1. 3. Tax Procedures and Documentation: The booklet outlines mandatory disclosures, including local files, master files, and Country-by-Country reports, with significant penalties for non-compliance.
  1. 4. Mitigating Risks in Related-Party Transactions: Strategies to minimize compliance risks include robust transfer pricing policies and potentially engaging in advance pricing agreements (APAs).

This booklet emphasizes the importance of understanding related persons under Egypt’s tax laws to ensure compliance, reduce penalties, and manage tax risks efficiently.

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Sohila Mahmoud - Transfer Pricing Lead

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