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TP Documentation in Egypt: A Guide to Ministerial Resolution

In the bid of to simplify compliance procedures and foster a more conducive business environment, the Egyptian Tax Authority (ETA) has recently introduced significant updates to the Transfer Pricing (TP) regulations. Ministerial Resolution No. 52 of 2024 raises the materiality threshold for TP documentation, while Transaction Pricing Explanatory Guide No. 78 of 2023 offers crucial clarifications on compliance requirements. These adjustments represent a positive stride towards easing tax obligations for companies involved in cross-border or local transactions within Egypt.

The notable increase from EGP 8 million to EGP 15 million in the materiality threshold under Ministerial Resolution No. 52 of 2024 acknowledges the importance of balancing a fair tax environment with reduced administrative burdens on taxpayers. By elevating the threshold, the ETA aims to provide companies with clearer guidelines and greater flexibility in fulfilling TP documentation requirements.

However, it’s imperative for companies to understand that despite the rise in the materiality threshold, TP regulations and compliance obligations remain intact. It’s crucial for businesses to maintain accurate and reliable TP documentation for transactions falling within and above the new threshold, as non-compliance could lead to penalties and repercussions from tax authorities.

The issuance of Transfer Pricing Explanatory Guide No. 78 of 2023 enhances clarity regarding TP regulations in Egypt. This comprehensive guide addresses common queries and concerns related to TP compliance, providing insights into dividend filing timelines, dividend processing, balance sheet transactions, and the responsibilities of joint ventures and free zone entities.

Key provisions highlighted in the guide include:

Local filing timeline: Companies are required to file locally within two months after the corporate income tax return, providing a clear timeframe for TP documentation preparation and submission, ensuring compliance with regulatory requirements.

Delay penalties: Notably, failure to submit TP documents will not incur late fines, offering relief to companies.


Dividends: dividends will not be treated as related-party transactions, simplifying compliance procedures for many businesses.

Balance sheet transactions: The guide underscores the disclosure of balance sheet transactions affecting the statement of financial position, particularly concerning minimum materiality documentation requirements. This clarification assists companies in understanding their reporting obligations and ensures transparency in financial disclosures.

Joint Ventures and Free Zone Entities: Offering definitions and clarifications on joint ventures and free zone entity obligations regarding master file submission, these insights are essential for companies operating within these frameworks to comply with TP documentation requirements effectively.

The implications of these updates for companies operating in Egypt are significant. The higher materiality threshold and explanations provided in the Explanatory Guide offer a clearer path to TP compliance. It’s essential for businesses to assess the impact of these changes on their operations and ensure compliance with all stipulated requirements to avoid penalties and maintain a cooperative relationship with tax authorities.

In conclusion, the Egyptian Tax Authority’s efforts to enhance compliance with transfer Pricing  through Ministerial Resolution No. 52 of 2024 and Transfer Pricing Explanatory Guide No. 78 of 2023 reaffirm its commitment to promoting a transparent and fair tax system. Companies should leverage these updates to review their practices and adapt them, accordingly, ensuring continued compliance and contributing to a favorable business environment in Egypt.

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Written By

Sohila Mahmoud - Transfer Pricing Lead

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