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Egypt’s Transfer Pricing Penalty Framework

Transfer pricing in Egypt has swiftly garnered global attention as an indispensable aspect of international business and finance. In contexts where promoting transparent business operations is of paramount importance, a profound comprehension of transfer pricing becomes imperative for multinational corporations.

Egypt’s Approach to Transparent Transfer Pricing:

Andersen recognizes that Egypt’s tax authorities have made commendable efforts to fortify the transfer pricing framework. This ensures that multinational companies present their transactions with related parties transparently. The outlined penalties in the Egyptian tax procedure law emphasize the country’s resolve for fairness in taxation. Andersen stands at the forefront, guiding businesses through these complexities to ensure compliance.

Why Compliance Matters in Egypt:

Transfer pricing extends beyond tax law compliance alone. In Egypt, the rigorous penalty structure serves as evidence of the nation’s commitment to fostering a transparent business ecosystem. Failures in disclosing information, submitting essential documents, or reporting cross-border activities are met with penalties, underscoring the imperative of comprehensive compliance.

Navigating the Egyptian Transfer Pricing Penalties:

  • 1% penalty for undisclosed related party transactions.
  • 3% penalty for not submitting the local file detailing transfer pricing.
  • 3% penalty for failing to provide the master file.
  • 2% penalty if the CbCR (Country-by-Country Report) isn’t submitted.

Documentation: The Key to Transparent Transfer Pricing:

For a thorough understanding and accurate representation of a company’s transfer pricing mechanisms, Egypt mandates the submission of both a local and master file. These files, crucial for the tax authorities, dive deep into a company’s transactional details and overall pricing strategies. Andersen assists businesses in understanding, compiling, and submitting these essential documents seamlessly.

  • Local File with Andersen: Gain a detailed, clear-cut view of individual transactions, ensuring accurate transfer pricing determinations.
  • Master File with Andersen: Develop a comprehensive strategy overview, detailing the rationale behind your pricing decisions.

Country-by-Country Reporting in a Global Era:

Given the global focus on transparency, Egypt prioritizes the CbCR, emphasizing its necessity through stipulated penalties for non-adherence. Andersen can assist companies in effectively compiling and submitting these reports, reinforcing cross-border transparency.


Egypt’s steadfast commitment to transfer pricing underscores its dedication to promoting global business transparency. In an ever-evolving and intricate business environment, Andersen remains a trusted ally for Egyptian enterprises, ensuring their adherence to transfer pricing regulations, championing a culture of fairness, and enhancing their reputation on the global stage.

Discover more about Andersen’s Transfer Pricing services.

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Written By

Sohila Mahmoud - Transfer Pricing Lead

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