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OECD Pillars in Egypt: A New Era for Digital Economy Taxation

In the evolving landscape of international taxation, the Organization for Economic Co-operation and Development (OECD) has introduced two significant frameworks known as Pillar One and Pillar Two. These frameworks aim to address the challenges posed by the digitalization of the economy and base erosion and profit shifting (BEPS) practices by multinational enterprises (MNEs). However, their implementation poses both challenges and opportunities for jurisdictions like Egypt, particularly concerning the application of domestic income tax laws and existing double tax treaties.

Pillar One: A Sustainable Taxation Framework for the Digital Economy

Pillar One is designed to deliver a sustainable taxation framework in today’s digitalized economy, ensuring fairness and more efficient allocation of taxing rights. It focuses on nexus and profit allocation, aiming to prevent the erosion of tax bases and the shifting of profits to low-tax jurisdictions by digital businesses. By reallocating taxing rights, Pillar One seeks to address the challenges of traditional tax rules that are no longer suitable for the digital economy.

In the case of Egypt, the implementation of Pillar One may require a reevaluation of its domestic income tax laws to accommodate new rules for nexus and profit allocation, especially concerning digital businesses. This may involve revisiting the definition of permanent establishment and revising transfer pricing regulations to ensure that profits are fairly allocated in line with economic activities conducted within Egypt.

Pillar Two: Ensuring a Minimum Level of Taxation for MNEs

Pillar Two aims to ensure that large MNEs pay a minimum level of tax on the income arising in each jurisdiction where they operate. This global minimum tax is intended to address remaining BEPS issues, such as profit shifting to low-tax jurisdictions and the use of aggressive tax planning strategies to minimize tax liabilities.

For Egypt, the implementation of Pillar Two may necessitate amendments to domestic tax laws to introduce a minimum effective tax rate for MNEs operating within its jurisdiction. This could involve the introduction of a top-up tax to ensure that MNEs pay a minimum level of tax on their profits, regardless of their tax planning strategies.

Cross-Border Services

Cross-border services are subject to taxation in Egypt. The VAT Law includes provisions for the taxation of services provided by non-residents to Egyptian businesses or individuals. It is essential for service providers to understand their obligations and potential VAT liability when offering services across borders.

Challenges and Opportunities for Egypt’s Tax Landscape

The implementation of OECD Pillar One and Pillar Two in Egypt poses several challenges and opportunities for the country’s tax landscape. On one hand, it offers an opportunity to modernize and align Egypt’s tax laws with international best practices, enhancing transparency and fairness in the tax system. On the other hand, it may increase the administrative burden on tax authorities and businesses, particularly concerning compliance with new rules and reporting requirements.

In addition, the impact of these frameworks on Egypt’s double tax treaties must be carefully considered. While the objectives of avoiding double taxation and preventing tax evasion remain paramount, adjustments may be needed to ensure that existing treaties are compatible with the principles of Pillar One and Pillar Two.

Comparison with Other Jurisdictions: KSA, and UAE

Other jurisdictions in the region, such as Saudi Arabia (KSA) and the United Arab Emirates (UAE), have also been grappling with the challenges posed by digitalization and BEPS practices. These countries have demonstrated varying degrees of flexibility in adapting their tax systems to accommodate new international tax frameworks.

For example, the UAE has implemented significant reforms in recent years to enhance its tax transparency and compliance measures, including the introduction of country-by-country reporting requirements and economic substance regulations.

Similarly, KSA has taken steps to strengthen its tax administration and enforcement capabilities, including the establishment of specialized tax tribunals to adjudicate tax disputes. And recently the KSA government introduced a proposed income tax law bill. the primary aim of this new tax law is to modernize and align the existing tax legislation with international best practices. Drawing inspiration from leading G20 nations and other progressive jurisdictions, the proposed laws seek to enhance efficiency and effectiveness in tax administration. Furthermore, the introduction of a new income tax law is designed to align with the Kingdom’s overarching vision and strategic objectives. Emphasis is placed on fostering foreign investment, stimulating domestic economic growth, and bolstering tax compliance and transparency. These efforts are also geared towards reinforcing the Kingdom’s commitment to international tax cooperation and its role as a pioneering contributor to global tax initiatives.

However, challenges remain, particularly concerning the interpretation and application of new tax rules and the coordination of tax policies at the regional level. Differences in legal systems, administrative capacities, and economic structures may also affect the implementation of OECD Pillar One and Pillar Two in these jurisdictions.

Readiness of Egypt’s Tax Management and Taxpayer Community

As Egypt prepares to digest the impact of the OECD Pillar One and Pillar Two, questions arise regarding the readiness of its tax management and taxpayer community to adapt to these changes. Are the current official tax management systems equipped to handle the administrative burden associated with the application of these frameworks? Is the taxpayer community aware of the implications of the top-up tax rate calculation and prepared to comply with new reporting requirements?

Furthermore, what impact will these changes have on tax planning efforts by tax experts? Will there be a need for adjustments to existing tax structures and strategies to ensure compliance with new rules and regulations? Additionally, are amendments to the tax law provisions and litigation environments necessary to align Egypt’s tax system with international best practices?


The implementation of OECD Pillar One and Pillar Two represents a significant milestone in the evolution of international taxation, with far-reaching implications for jurisdictions like Egypt. While these frameworks offer opportunities to enhance fairness and transparency in the tax system, they also pose challenges in terms of administrative complexity and compliance costs.

To effectively navigate these challenges, Egypt must ensure that its tax management systems are equipped to handle the increased administrative burden and that its taxpayer community is adequately informed and prepared to comply with new requirements. Furthermore, adjustments may be needed to existing tax laws and treaties to align with the principles of Pillar One and Pillar Two while safeguarding the objectives of avoiding double taxation and preventing tax evasion. Ultimately, by embracing these changes and adopting a proactive approach to tax reform, Egypt can position itself as a competitive and attractive destination for investment in the digital age.

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Written By

Hamdy Yahia - Tax Partner

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