Law No. 91 of 2005 Promulgating Law
Article (1)
The provisions of the attached Law shall apply to income tax.
Article (2)
The Income Tax Law promulgated by Law No. 157 of 1981 is repealed. However, the appeal committees constituted under that Law shall continue until 31 December 2005 to consider tax disputes relating to the years ending in 2004. Any disputes not determined by that date shall be referred, in their existing state, to the committees constituted under the attached Law. Fixed-term exemptions under the repealed Law shall remain effective for persons whose exemption periods began before this Law came into force, until those periods expire. Item (1) of Article (1) of Law No. 147 of 1984 imposing a State Financial Resources Development Duty is also repealed.
Article (3)
Articles 16, 17, 18, 19, 21, 22, 23 bis, 24, 25 and 26 of the Investment Guarantees and Incentives Law promulgated by Law No. 8 of 1997 are repealed. The exemptions provided in those Articles shall remain effective for companies and establishments whose exemption periods began before this Law came into force, until the prescribed periods expire. Companies and establishments formed under that Law that had not commenced their activity or production when this Law came into force must commence their activity or production within three years of its commencement to benefit from the exemptions provided under that Law.
Article (4)
Every person shall be exempt from all income tax and general sales tax due for tax periods preceding the commencement of this Law, together with related late-payment charges, fines, additional tax and other amounts, subject to both of the following conditions:
1. The person has not previously been registered, submitted a tax return, or undergone any form of tax review by the Egyptian Tax Authority.
2. Within one year of the commencement of this Law, the taxpayer submits a return for the latest tax period containing all relevant information and applies for registration with the Egyptian Tax Authority if the registration threshold is reached.
The exemption shall lapse if the taxpayer fails to submit income tax returns regularly for the following three tax periods.
Article (5)
Proceedings in all actions registered or pending before courts of any degree between the Tax Authority and taxpayers concerning the assessment of tax shall terminate where the disputed annual tax base does not exceed EGP 10,000. No claim shall be made for unpaid taxes relating to those actions. Termination does not entitle the taxpayer to recover amounts previously paid on account of tax on the disputed base. This shall apply unless the taxpayer requests that the proceedings continue by applying to the court hearing the action within six months of this Law coming into force.
Constitutional note: the words ‘before 1 October 2004’ in the original provision were held unconstitutional by the Supreme Constitutional Court in Case No. 229 of Judicial Year 29, judgment of 12 May 2013; they have therefore not been retained as an operative condition in this translation.
Article (6)
For actions other than those specified in Article (5) of this promulgating Law, taxpayers with disputes pending between them and the Tax Authority and registered or being heard before courts of any degree may request termination of those disputes within one year of this Law coming into force, against payment of a percentage of the tax and other amounts due on the disputed annual tax base according to the following brackets:
1. 10% of the tax and other amounts due on the disputed base where that base does not exceed EGP 100,000.
2. 25% of the tax and other amounts due on the portion of the disputed base exceeding EGP 100,000 and not exceeding EGP 500,000, after paying the percentage specified in item (1) on the portion not exceeding EGP 100,000.
3. 40% of the tax and other amounts due on the portion of the disputed base exceeding EGP 500,000, after paying the percentages specified in items (1) and (2) on the portion not exceeding EGP 500,000.
Payment of these percentages discharges the taxpayer from the disputed tax and other amounts. The court shall terminate the proceedings if the taxpayer provides evidence of payment. Termination does not entitle the taxpayer to recover any amounts previously paid on account of the disputed tax.
Constitutional note: the words ‘before 1 October 2004’ in the first paragraph were held unconstitutional by the Supreme Constitutional Court in Case No. 123 of Judicial Year 31, published in the Official Gazette on 9 April 2016; they have therefore not been retained as an operative condition in this translation.
Article (7)
As an exception to Article (52), item (1), of the attached Law, interest on loans and advances obtained by legal persons shall be deductible on amounts exceeding four times average equity, up to eight times average equity, during the period from tax year 2005 through the end of tax year 2009, according to the following schedule:
• 8:1 for the taxation year 2005
• 7:1 for the taxation year 2006
• 6:1 for the taxation year 2007
• 5:1 for the taxation year 2008
• 4:1 for the taxation year 2009
Article (8)
The Minister of Finance shall issue the Executive Regulations of this promulgating Law and the attached Law within six months of publication in the Official Gazette. Until those Regulations are issued, existing regulations and decisions shall remain effective insofar as they do not conflict with either Law.
Article (9)
This Law shall be published in the Official Gazette and shall come into force on the day following publication, subject to the following:
1. The provisions of the attached Law shall apply to salaries and equivalent remuneration from the first day of the month following publication in the Official Gazette.
2. The provisions of the attached Law shall apply to natural persons’ commercial and industrial income, non-commercial professional income and real estate income from tax period 2005. They shall apply to the profits of legal persons from tax period 2005 or from the legal person’s tax period beginning after this Law comes into force.
This Law shall bear the seal of the State and be enforced as one of its laws.
The Income Tax Law Attached Law
Book One – General Provisions
Article (1)
For the purposes of implementing the provisions of this law, the following terms and expressions shall have the meanings set forth opposite each of them:
• Tax: Income tax
• Minister: Minister of Finance
• Head of the Authority: Head of the Egyptian Tax Authority
• The Authority: The Egyptian Tax Authority
• Taxpayer: A natural or legal person subject to tax in accordance with the provisions of this law
• Capital Companies: Joint stock companies, partnerships limited by shares, and limited liability companies
• Partnerships: General partnerships and limited partnerships
• De facto Company: A company formed or continued between natural persons without fulfilling the procedures for formation or registration. A sole proprietorship transferred through inheritance shall not be considered a de facto company, provided that a single tax return is submitted reflecting each heir’s share therein
• Project: An economic entity engaged in its core activity in Egypt or a permanent establishment in Egypt affiliated with a foreign economic entity
• Related Person: Any person who has a relationship with a taxpayer that influences the determination of the tax base, whether directly or indirectly, through management, control, or ownership. In general, two persons shall be considered related if the relationship between them allows either or both to act according to the directions, requests, suggestions, or will of the other person or a third party. The following persons shall be treated as related persons:
• Spouses, ancestors, and descendants.
• Partnerships and their general and limited partners.
• Capital companies and any person directly or indirectly owning at least 50% of the voting rights, management rights, profit distribution rights, or capital rights in the company.
• Any two or more companies in which another person owns at least 50% of the voting rights, management rights, profit distribution rights, or capital rights. In applying items 2, 3, or 4 above, holdings attributed to a person through a related person shall not be attributed to another related person. Two persons shall not be considered related solely on the basis that one is an employee or agent of the other, or that both are employees or agents of a third party, unless such relationship influences the determination of the tax base, directly or indirectly.
• Arm’s Length Price: The price at which transactions are conducted between two or more unrelated parties, determined according to market forces and transaction conditions.
• Royalties: Any payments of any kind received as consideration for the use of, or the right to use, copyrights in literary, artistic, or scientific works, including cinematographic films; or for the use of, or the right to use, any patent, trademark, design, model, plan, formula, or secret process; or for the use of, or the right to use, industrial, commercial, or scientific equipment or information relating to industrial, commercial, or scientific experience.
Dividend Distributions: Any income derived from shares or ownership interests, including enjoyment shares or enjoyment rights, mining shares, founders’ shares, or other rights conferring participation in profits, whether distributed in cash, bonus shares, bonds, founders’ interests or any other form.
• Civil Companies: Non-commercial companies established in accordance with the provisions of the Civil Code or any other law.
Article (2)
In application of this law, the natural person shall be considered as residing in Egypt in any of the following cases:
• If he has a permanent residence in Egypt.
• If he resides in Egypt for a period exceeding 183 days either consecutive or interrupted during twelve months.
• The Egyptian national who performs the duties of his job abroad and receives his income from the Egyptian treasury. The corporate body shall be deemed as residing in Egypt in any of the following cases:
• If it has been established subject to Egyptian law.
• If its principal or effective place of management is in Egypt.
• If it is a company in which the State or a public legal person owns more than 50% of the capital.
The Executive Regulations shall set out the rules for determining permanent domicile and the effective place of management.
Article (3)
Income derived from a source in Egypt includes the following:
• Income from services performed in Egypt, including salaries and equivalent remuneration.
• Income borne by an employer resident in Egypt, even if the work is performed abroad.
• Income earned by an athlete or artist from activities carried out in Egypt.
• Income from activities performed by a non-resident through a permanent establishment in Egypt.
• Income from the disposal of movable property belonging to a permanent establishment in Egypt.
• Income from the exploitation and disposal of real estate and similar assets located in Egypt, including real estate by appropriation.
• Dividends on shares of a capital company resident in Egypt.
• Profit shares distributed by a partnership resident in Egypt.
• Interest paid by the government, local administrative units, public legal entities, or any person resident in Egypt, and interest paid by a permanent establishment in Egypt, even if its owner is not resident therein.
• Rental amounts, license fees, and royalties borne by a person resident in Egypt or by a permanent establishment in Egypt, even if its owner is not resident therein.
• Income from any other activity conducted in Egypt.
• Capital gains realized from the disposal of securities listed on the Egyptian Stock Exchange, as well as capital gains realized from the disposal of securities of resident Egyptian companies not listed on the Egyptian Stock Exchange, whether or not they are listed abroad.
Article (4)
For the purposes of applying the provisions of this law, a “permanent establishment” refers to any fixed place of business through which the business of a non-resident person is wholly or partially carried out. This includes, in particular:
• Place of management
• Branch
• Office
• Factory
• Workshop
• Mine, oil field, gas well, quarry, or any other place of extraction of natural resources, including timber or other forest products
• Farm or plantation
• Buildings, facilities, or warehouses used as sales outlets
• A construction or building site, installation or assembly project, or related supervisory activities, provided the site, project, or activities continue in Egypt for a period or periods exceeding in total 90 days within any 12-month period. Also considered as constituting a permanent establishment are the following:
• Any activities carried out in Egypt related to the exploration, extraction, or exploitation of natural resources, including the use or installation of substantial equipment, provided such activities exceed in total 90 days within any 12-month period.
• The provision of services, including consultancy services, by an enterprise through employees or other personnel engaged for such purpose, where the services are performed in Egypt for the same project or a related project for a period or periods exceeding in total 90 days within any 12-month period.
• An insurance enterprise resident in another country, except with respect to reinsurance, where it collects premiums in Egypt or insures risks located in Egypt through a person other than an independent agent.
(d) Where a person in Egypt acts on behalf of an enterprise in another State and carries on business in Egypt as an independent agent, acting for the enterprise in the ordinary course of that person’s business. However, where that person acts exclusively or almost exclusively on behalf of one or more enterprises to which the person is closely related, that person shall not be considered an independent agent within the meaning of this paragraph in relation to any such enterprise.
(e) A person acting on behalf of an affiliated enterprise who has authority to conclude and approve contracts in the enterprise’s name, unless the person’s activities are limited to purchasing goods or merchandise for the enterprise. This also applies where that person habitually concludes contracts, or habitually plays the principal role leading to contracts routinely concluded without material modification by the enterprise, and those contracts:
1. Are in the enterprise’s name;
2. Transfer ownership of, or grant the right to use, property owned by the enterprise or which the enterprise has the right to use; or
3. Provide services supplied by the enterprise.
(f) Projects or activities exceeding 90 days where:
1. An enterprise of a non-resident company carries on activities in Egypt at a location constituting a construction site, building project, installation or another project specified in the first paragraph of this Article, or performs related supervisory or consultancy activities at that location; and
2. Connected activities are carried out in Egypt at the same site, project or other location specified in that paragraph, including related supervisory or consultancy activities, during different periods by one or more enterprises closely related to that enterprise.
Those different periods shall be added to the total period during which the first-mentioned enterprise carries on its activities at the construction site, building project, installation or other location specified in the first paragraph of this Article.
Article (4 Bis)
As an exception to Article (4), none of the following shall constitute a permanent establishment:
• The use of facilities solely for the purpose of storing or displaying goods or merchandise belonging to the enterprise.
• The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display.
• The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise.
• The use of a fixed place of business solely for the purpose of purchasing goods or merchandise or collecting information for the enterprise.
• The use of a fixed place of business solely for the purpose of carrying out any other activity of a preparatory or auxiliary character for the enterprise.
• The use of a fixed place of business solely for the combination of any activities mentioned in items (a), (b), (c), (d), or (e) above, provided that the overall activity of the fixed place of business resulting from the combination is of a preparatory or auxiliary character.
• A company resident in another country that is under the control of a company resident in Egypt or carries on business in that other country. The activities listed in this article shall also not constitute a permanent establishment when performed by a person acting on behalf of an affiliated enterprise, provided that such person does not play any role in concluding contracts. However, the provisions of this article shall not apply to any fixed place of business that is used or maintained by an enterprise, or by a closely related enterprise, that carries out business activities in the same location or in another location in Egypt, if:
• That location or the other location constitutes a permanent establishment for the enterprise or its closely related enterprise under the provisions of this article;
• The overall activity resulting from the combination of activities carried out by both enterprises at the same location, or by the same enterprise or closely related enterprises at both locations, is not of a preparatory or auxiliary character, provided that the activities performed constitute complementary functions that are part of a cohesive business operation. A person shall be considered closely related to an enterprise based on all relevant facts and circumstances, including where one controls the other or both are under the control of the same persons or enterprises. In any case, a person shall be deemed closely related to an enterprise if one directly or indirectly owns more than 50% of the total shares, voting rights, or equity interests in the other.
Article (5)
The tax period is the financial year beginning on 1 January and ending on 31 December, or any twelve-month period used as the basis for calculating tax. Tax may be calculated for a period shorter or longer than twelve months; the Executive Regulations shall prescribe the assessment procedures for such a period. Tax becomes due on the day following the end of the tax period. It also becomes due on the taxpayer’s death, cessation of residence, or complete cessation of activity.
Book Two – Income Tax on Natural Persons
Part One – Scope of Tax Application & Rates
Article (6)
An annual tax shall be imposed on the total net income of resident natural persons with respect to their income realized in Egypt or abroad if Egypt is the center of their commercial, industrial, or professional activity, and the tax shall likewise apply to the income of non-resident natural persons with respect to their income realized in Egypt. The total net income is composed of the following sources: 1- Salaries and the like. 2- Commercial or industrial activity. 3- Professional or non-commercial activity. 4- Real estate wealth.
Article (7)
Repealed pursuant to Article 2 of Law No. 101 of 2012 concerning the amendment of the provisions of the Income Tax Law.
Article (8)
The tax rate shall be as follows:
| Total annual net income EGP | Taxable income slice EGP | Rate |
| Up to 600,000 | 1-40,000 | 0% |
| Up to 600,000 | Over 40,000 to 55,000 | 10% |
| Up to 600,000 | Over 55,000 to 70,000 | 15% |
| Up to 600,000 | Over 70,000 to 200,000 | 20% |
| Up to 600,000 | Over 200,000 to 400,000 | 22.5% |
| Up to 600,000 | Over 400,000 | 25% |
| Over 600,000 to 700,000 | 1-55,000 | 10% |
| Over 600,000 to 700,000 | Over 55,000 to 70,000 | 15% |
| Over 600,000 to 700,000 | Over 70,000 to 200,000 | 20% |
| Over 600,000 to 700,000 | Over 200,000 to 400,000 | 22.5% |
| Over 600,000 to 700,000 | Over 400,000 | 25% |
| Over 700,000 to 800,000 | 1-70,000 | 15% |
| Over 700,000 to 800,000 | Over 70,000 to 200,000 | 20% |
| Over 700,000 to 800,000 | Over 200,000 to 400,000 | 22.5% |
| Over 700,000 to 800,000 | Over 400,000 | 25% |
| Over 800,000 to 900,000 | 1-200,000 | 20% |
| Over 800,000 to 900,000 | Over 200,000 to 400,000 | 22.5% |
| Over 800,000 to 900,000 | Over 400,000 | 25% |
| Over 900,000 to 1,200,000 | 1-400,000 | 22.5% |
| Over 900,000 to 1,200,000 | Over 400,000 | 25% |
| Over 1,200,000 | 1-1,200,000 | 25% |
| Over 1,200,000 | Over 1,200,000 | 27.5% |
For calculating tax, total annual net income shall be rounded down to the nearest EGP 10. The schedule above applies according to the taxpayer’s total annual net income category; each row identifies the income slice taxed at the stated rate.
Part Two – Salaries and Its Equivalent
Article (9)
Tax shall be applicable to salaries and its equivalent as follow:
• All amounts due to taxpayer as a result of working for other by or without a contract either regularly or irregularly whatsoever the names, forms or reasons for such dues, and whether such amounts have become due for works rendered in Egypt or abroad and its consideration has been paid by any party in Egypt including wages, remunerations, incentives, commissions, grants, overtime, allowances, quotas or shares in profits as well as cash and non-cash benefits of whatsoever kind.
• Amounts due to taxpayer from source outside Egypt for works performed in Egypt.
• Salaries and remunerations of the chairmen and board members in public and public business sector companies who are not shareholders in such companies.
• Salaries and remuneration of chairpersons, board members and managers of capital companies in consideration of their administrative work.
The Executive Regulations shall determine the basis for valuing benefits in kind.
Article (10)
For each part of the year in which taxable income is received, the income included in the tax base shall be determined in proportion to that part of the year, on the basis of monthly income converted to an annual amount. If taxable income changes, its calculation shall be adjusted from the date of the change using the new income or the previous income, whichever is lower, after annualisation. An annual reconciliation shall be made under the procedures and rules prescribed by the Executive Regulations.
Salary and wage arrears and equivalent remuneration paid as a lump sum in a year shall be allocated to the years in which they accrued, except payments in lieu of leave. The income included in the tax base for each year shall be recalculated and the tax due reconciled accordingly.
Article (11)
Repealed pursuant to Article 8 of Law No. 30 of 2023 concerning the amendment of the provisions of the Income Tax Law.
Article (12)
The following shall not be subject to tax:
• Pensions
• End of service remunerations.
Article (13)
Without prejudice to other tax exemptions granted under special laws, the following shall be exempt from income tax:
• An annual personal exemption of EGP 20,000 for the taxpayer.
• Social insurance contributions and other deductions made in accordance with the provisions of social insurance laws or any alternative systems.
• Employee contributions to private insurance funds established in accordance with the provisions of the Private Insurance Funds Law issued under Law No. 54 of 1975.
• Premiums paid for life insurance and health insurance for the benefit of the taxpayer, their spouse, or minor children, as well as any insurance premiums for pension entitlements.
• The following collective in-kind benefits: o Meals provided to employees o Group transportation for employees or the equivalent cost thereof o Healthcare services o Tools and uniforms necessary for performing the job. o Housing provided by the employer to employees in connection with the performance of their work.
• Employees’ share of profits distributed in accordance with the law.
• Income received by members of the diplomatic and consular corps, international organizations, and other foreign diplomatic representatives, within the scope of their official duties, provided that reciprocal treatment is applied and only to the extent of such reciprocity. Conditions for Exemptions under Items (3) and (4): To apply the exemptions listed in items (3) and (4), the total exempted amount must not exceed 15% of the net income or EGP 10,000, whichever is lower. The contributions and premiums referred to in these two items may not be claimed again as exemptions under any other type of income specified in Article (6) of this law.
Article (14)
Employers and persons obligated to pay taxable revenues — including companies and projects established under the Free Zones system — shall withhold, from the amounts payable by them as specified in Article (9) of this Law, an amount on account of the tax due, in accordance with what is prescribed by the Executive Regulations of this Law. They shall remit to the competent Tax Authority, within the first fifteen (15) days of each month, the amounts withheld from the payments of the preceding month. Employers and persons obligated to pay the revenue shall settle any tax differences due, all without prejudice to their right of recourse against the taxpayer for the amounts owed by him.
Article (15)
[Repealed by Law No. 206 of 2020 (Unified Tax Procedures Law).]
Article (16)
If the employer or person liable to pay taxable income is not resident in Egypt or has no office or establishment there, the recipient of the taxable income shall be responsible for remitting the tax under the rules and procedures prescribed by the Executive Regulations.
Part Three – Commercial and Industrial Activity
Article (17)
The profits of commercial and industrial activity shall be determined on the basis of the revenue arising from all commercial and industrial operations realized in Egypt, as well as revenues realized from abroad if Egypt is the center of the taxpayer’s commercial and industrial activity, including the profits arising from the sale of the establishment’s assets provided for in items (1), (2), (4) of Article (25) of this Law, and the profits realized from the compensations obtained by the taxpayer as a result of the destruction or expropriation of any of these assets and securities, as well as the liquidation profits realized during the tax period, all of that after deducting all deductible costs. Net profit shall be determined on the basis of the income statement prepared in accordance with the Egyptian Accounting Standards, and the tax base shall be determined by applying the provisions of this Law to the said net profit.
Article (18)
[Repealed by Law No. 151 of 2026.]
Chapter One – Taxable Revenues
Article (19)
Tax shall apply to profits of the commercial and industrial activity including:
• Profits of commercial or industrial establishments, mines, quarries and oil.
• Profits of craftsmen and small – scale activities.
• Profits provided by any commercial or industrial activity even if it is limited to single transaction and the executive regulation of this law indicates the rules of considering the activity as single transaction for the application of this item.
• Profits realized as a result of operation or operations carried out by brokers or agents with commission, in general, each profit realized by any person practicing brokerage for purchasing, selling or leasing real estate or any kind of goods, services or movable property.
• Profits resulting from leasing commercial or industrial place whether lease included all or some of tangible or intangible components as well as profits resulting from hiring mechanical and electrical machinery except agricultural tractors, irrigation machines & its accessories, machinery & equipment used in agriculture.
• Profits provided by all kinds of transportation activity.
• Profits realized by practicing construction or purchasing real estate for their own account for regular sale whether profits resulted from selling the real estate property as a whole or divided into apartments, rooms, administrative or commercial units or other.
• Profits from division of land for the purpose of disposal or building.
• Profits of land reclamation or cultivation establishments, poultry-rearing or mechanical-hatching projects, animal-rearing facilities, livestock-rearing and fattening facilities exceeding twenty head, and fish-farming and fisheries projects.
Tax shall also apply to profits from investing in, or disposing of, securities abroad.
Article (20)
Tax shall not apply to profits resulting from the revaluation of a sole proprietorship’s assets when contributed in kind to the capital of a joint-stock company, provided that the shares issued in exchange for that contribution are registered shares and are not disposed of before five years have elapsed.
Article (21)
An establishment’s taxable net profit from all long-term contracts to which it is a party shall be determined according to the percentage of each contract completed during the tax period. That percentage shall be the actual cost of work completed up to the end of the tax period divided by the total estimated cost of the contract. The estimated profit is the contract value less its estimated costs.
The estimated profit for each tax period shall be the same proportion of that estimated profit as the proportion of work completed during the period. In the tax period in which the contract is completed, its profit shall be reconciled using actual revenue less actual costs, after deducting profits previously assessed.
If the tax period in which the contract is completed closes with a loss, that loss shall be deducted from profits of the earlier tax period or periods during which the contract was scheduled to be performed, up to the contract profits in those periods. Tax shall be recalculated accordingly and the taxpayer shall recover any overpayment. Any loss exceeding those limits shall be carried forward under Article (29).
For this Article, a long-term contract means a manufacturing, preparation, construction or related-services contract performed by the establishment for another person for a specified value, where performance extends over more than one tax period.
Chapter Two – Determination of Income Included in the Tax Base
Article (22)
The net taxable commercial and industrial profits shall be determined based on the gross profit after deducting all costs and expenses necessary for generating such profits. Deductible costs and expenses must meet the following conditions:
• They must be related to the commercial or industrial activity of the establishment and necessary for carrying out such activity.
• They must be genuine and supported by invoices or electronic receipts— electronic invoices starting from July 2023 and electronic receipts starting from January 2025. The Minister may extend either of these deadlines for a period not exceeding one year, as specified in the Executive Regulations of this Law. This requirement does not apply to costs and expenses that are customarily not supported by documentation. The Minister may also exempt certain costs and expenses from the requirement of being evidenced by electronic invoices or electronic receipts.
Article (23)
The following, in particular, are deductible costs and expenses:
1. Interest on loans used in the activity, whatever their amount, after deducting credit interest that is not subject to tax or is exempt by law.
2. Depreciation of the establishment’s assets under Article (25).
3. Duties and taxes borne by the establishment, other than the tax paid by the taxpayer under this Law.
4. Social insurance contributions payable by the establishment’s owner for employees and for the owner, paid to the National Social Insurance Authority.
5. Amounts set aside annually from the establishment’s funds or profits for private savings, pension or other funds, whether established under the Private Insurance Funds Law No. 54 of 1975, Law No. 64 of 1980 on alternative private social insurance systems, or a scheme governed by special rules or terms, up to 20% of total employee salaries and wages. The scheme which the establishment undertakes to implement must have rules or special terms stipulating that the establishment’s payments correspond to an end-of-service gratuity or pension. The scheme’s funds must be separate or independent from those of the establishment and invested for the scheme’s own account.
6. Insurance premiums contracted by the taxpayer against disability or death or to obtain a sum or income, up to EGP 3,000 per year.
7. Donations to the Government, local administration units and other public legal persons, whatever their amount.
8. Donations and subsidies to Egyptian civil associations and institutions registered under their governing laws, educational establishments and hospitals under government supervision, and Egyptian scientific research institutions, up to 10% of the taxpayer’s net annual profit.
9. Financial penalties and compensation due from the taxpayer as a result of contractual liability.
10. The solidarity contribution under Article (40), item Ninth, of the Comprehensive Health Insurance System Law promulgated by Law No. 2 of 2018.
Article (24)
The following shall not be considered deductible costs and expenses:
• Provisions and reserves of all kinds.
• Fines, financial penalties and compensation imposed on the taxpayer because the taxpayer or a person acting under the taxpayer’s authority committed a felony or intentional misdemeanour.
• Income tax payable under this law.
• Interest paid on loans to the extent that it exceeds twice the credit and discount rate announced by the Central Bank at the beginning of the calendar year in which the tax period ends.
• Returns on loans and debts of all kinds paid to natural persons who are not subject to tax or are exempt from it.
• Financing and investment costs related to income exempted from tax by law. The Executive Regulations shall specify the method for calculating these costs.
Article (25)
Depreciation of the establishment assets shall be calculated as follow:
1. 5% of the cost of purchasing, constructing, developing, renovating or reconstructing buildings, establishments, installations, ships and aircraft, for each tax period.
2. 10% of the cost of purchasing, developing, improving or renewing purchased intangible assets, including goodwill, for each tax period.
3. The following two categories of assets shall be depreciated using the depreciation-basis system at these rates:
(a) Computers, information systems, software and data-storage equipment: 50% of the depreciation basis for each tax year.
(b) All other business assets: 25% of the depreciation basis for each tax year.
4. No depreciation shall be calculated for land, works of art, antiquities, jewellery or other establishment assets that are inherently non-depreciable.
Article (26)
For Article (25), the depreciation basis means the book value of assets in the opening balance sheet for the tax period. It increases by the cost of assets used and the cost of development, improvement, renewal or reconstruction during that period. It decreases by annual depreciation, the sale value of disposed assets, and compensation received for assets lost or destroyed during the period.
If the depreciation basis is negative, the disposal value or compensation shall be added to the taxpayer’s commercial and industrial profits. If the depreciation basis does not exceed EGP 10,000, the entire basis shall be treated as a deductible cost.
Article (27)
Upon the taxpayer’s request, 30% of the cost of machinery and equipment used in investment in the production sector—whether new or used—may be deducted in the first tax period during which those assets are utilized. The depreciation basis stipulated in Article (25) of this law shall be calculated for that tax period after deducting the aforementioned 30%. If the mentioned request is not submitted, the depreciation rates provided in Articles (25) and (26) of this law shall apply. A condition for applying the provisions of the preceding two paragraphs is that the taxpayer maintains regular books and accounts.
Article (28)
The deduction of the bad debts which the taxpayer has written off from the establishment’s books and accounts shall be permitted, if he submits a report from one of the accountants registered in the Register of Accountants and Auditors evidencing the fulfilment of the following conditions: 1- That the establishment maintains regular accounts. 2- That the debt is connected to the activity of the establishment. 3- That the amount corresponding to the debt was previously included within the accounts of the establishment. 4- That the establishment has taken serious measures to collect the debt and has been unable to collect it after twelve months from the date of its maturity. The following shall be considered among the serious measures to collect the debt: (a) Obtaining a payment order in the cases in which that is permissible. (b) The issuance of a judgment from a court of first instance obliging the debtor to pay the value of the debt. (c) Claiming the debt in the proceedings for enforcing a judgment of the debtor’s bankruptcy, or his conclusion of a protective composition against bankruptcy. Excepted from the provision of the aforementioned item (4) are the bad debts which do not exceed the amount of 10,000 Egyptian pounds per single debt, on condition that the total of the bad debts does not exceed the ratio of (1%) of the total balance of the taxpayer’s debtors at the end of the tax year, in accordance with what is regulated by the Executive Regulations of this Law. If the debt or a part of it is collected, what has been collected must be included within the revenues of the establishment in the year in which the collection took place.
Article (29)
If the account of one of the years is closed with a loss, this loss shall be deducted from the profits of the following year; and if a part of the loss remains thereafter, it shall be carried forward annually to the following years up to the fifth year, and thereafter it is not permissible to carry forward any part of the loss to the account of another year.
Article (29 Bis)
[Repealed by Article 6 of Law No. 151 of 2026.]
Article (30)
Where related persons set conditions in their commercial or financial transactions that differ from those agreed between unrelated persons and may reduce the tax base or transfer the tax burden from a taxable person to an exempt or non-taxable person, the Authority may determine taxable profit using the arm’s length price. The Head of the Authority may enter into agreements with related persons to apply one or more methods for determining the arm’s length price in their transactions. The Executive Regulations shall determine those methods.
Chapter Three – Exemptions
Article (31)
The following shall be exempt from tax: 1- The profits of land reclamation or land cultivation establishments, for a period of ten years starting from the date of commencing the activity. 2- The profits of poultry-production establishments, bee-keeping, and the yards for the breeding and fattening of livestock, and the projects of fisheries and fish farms, and the profits of fishing-boat projects, for a period of ten years from the date of commencing the activity. 3- Repealed. 4- Repealed. 5- The returns obtained by natural persons on the deposits and savings accounts with banks registered with the Central Bank of Egypt, the investment, savings and deposit certificates issued by those banks, the deposits and savings accounts in the post-office funds, and the securities and deposit certificates issued by the Central Bank. 6- The profits realized from the new projects established with financing from the Social Fund for Development, within the limit of the ratio of this financing to the invested capital, with a maximum equivalent to fifty thousand pounds, and to the extent not exceeding (50%) of the annual profit, for a period of five years starting from the date of commencing the activity or the start of production, as the case may be, on condition of keeping regular books and accounts. 7- The capital gains realized from the disposal of securities listed on the Egyptian Exchange, with it not being permissible to deduct the losses resulting from these disposals or to carry them forward to following years. Excepted from that are the capital gains realized from the disposal of securities listed on the Egyptian Exchange upon whose disposal there results the striking-off of the listing of the company’s shares from the Exchange.
Part Four – Revenues of Non- Commercial Professions
Chapter One – Taxable Revenues
Article (32)
Tax shall be imposed on: 1- The net revenues of the liberal (free) professions and other non-commercial professions which the taxpayer practices independently, and in which work is the essential element, if they arise from practicing the profession or the activity in Egypt, as well as the revenues of the liberal professions and other non-commercial professions realized abroad if Egypt is the center of his professional activity. 2- The income received by the owners of intellectual property rights from the sale or exploitation of their rights, in Egypt or outside it. 3- Any revenues arising from any profession or activity not provided for in Article (6) of this Law, whether these revenues are realized in Egypt or abroad, if Egypt is the center of the profession or the activity.
Article (33)
The revenues included in the tax base shall be determined annually on the basis of the net revenues during the preceding year. The revenue from the non-commercial professions shall include the proceeds of the disposal of any professional assets, the proceeds of transferring expertise or of the assignment (relinquishment) of the offices of practicing the profession, wholly or partially, and any sums collected as a result of closing the office. The net revenues shall be determined on the basis of the revenue arising from the various operations pursuant to the provisions of this Law, after deducting all the costs and expenses necessary for carrying on the profession, including the depreciation of the assets, in accordance with simplified accounting principles for which a decision shall be issued by the Minister. The following shall be regarded as deductible costs: 1- Registration fees, annual subscriptions, and profession-practice fees. 2- The taxes paid by the taxpayer on the occasion of carrying on the profession, except the tax he pays pursuant to this Law. 3- The amounts paid by the taxpayer to his syndicate in accordance with its pension system. 4- The premiums of life and health insurance on the taxpayer for his benefit and the benefit of his spouse and minor children. 5. The solidarity contribution provided for in Article (40), item Ninth, of the Universal Health Insurance System Law referred to above.
In applying items (3) and (4) of the third paragraph of this Article, the total of what is exempted for the taxpayer must not exceed (15%) of the net revenue subject to tax, or the amount of (10,000) pounds annually, whichever is less. It is not permissible to repeat the same deduction from any other income provided for in Article (6) of this Law.
Article (34)
Donations paid to, or devolving to, the Government, local administration units and public legal persons shall be deducted from the net income specified in Article (32), up to the amount of net annual income. Donations and subsidies paid to Egyptian civil associations and institutions registered under their governing laws, educational establishments and hospitals under government supervision, and Egyptian scientific research institutions shall also be deductible, up to 10% of net annual income. The same donations may not be deducted from any other income specified in Article (6).
Article (35)
All costs and expenses necessary to generate income shall be deducted from the taxpayer’s gross income on the basis of regular accounts supported by documents. This includes costs and expenses not customarily supported by documents, as prescribed by the Executive Regulations. Where regular books are not maintained, the deduction shall be 10%. Article (29) shall apply for purposes of this Part where the taxpayer maintains regular books.
Chapter Three – Exemption from Tax
Article (36)
The following shall be tax exempt:
1. Repealed.
2. Income from writing and translating religious, scientific, cultural and literary books and articles, except income from selling the work or translation for production in visual or audio form.
3. Income of teaching staff at universities and institutes, and others, from their works and compilations originally printed for distribution to students under the systems and prices determined by those universities and institutes.
4. Income of members of the Plastic Artists Syndicate from producing works of painting, sculpture and engraving.
5. Net income of independent professionals registered as active members of professional syndicates in their fields of specialisation, for three years from commencing professional practice, up to EGP 50,000 annually. They shall become liable to tax only from the first day of the month following expiry of that exemption period, extended by the training period required under the law governing the profession and any period of public service, military service or reserve call-up occurring after commencement of practice. The exemption period is reduced to one year for a person commencing practice for the first time more than fifteen years after graduation.
Part Five – Revenues of Real Estate Wealth
Chapter One – Taxable Revenues
Article (37)
The taxable revenues shall include:
• Revenues from built properties leased in accordance with the provisions of the Civil Code.
• Revenues from furnished units.
Chapter Two – Determining the Revenues
Article (38)
[Repealed by Article 2 of the Real Estate Tax Law No. 196 of 2008.]
Article (39)
The taxable income derived from leasing-built properties or parts thereof, in accordance with the provisions of the Civil Code, is determined based on the actual rent received, with a deduction of 50% to cover all costs and expenses.
Article (40)
[Repealed by Article 2 of the Real Estate Tax Law No. 196 of 2008.]
Article (41)
Tax shall be applicable to revenues resulting from leasing any furnished unit or part thereof whether it has been prepared for housing or practicing commercial or industrial activity or non- commercial profession or any other purpose. The taxable revenue shall be fixed on the basis of the actual rental less 50% for all costs and expenses
Article (42)
Tax is imposed at 2.5%, without any reduction, on the total value of disposals of built properties or land designated for building, excluding villages, however numerous the disposals. This applies whether the property or land is disposed of as it stands or after buildings have been erected, whether the disposal covers the whole property, part of it, a residential unit or otherwise, whether the buildings stand on land owned by the taxpayer or by another person, and whether the disposal contracts are registered or unregistered.
The first paragraph applies to an heir’s disposal of inherited property or land, as inherited or after buildings have been erected for the heir’s own use. It also applies to disposal of the specified built properties or land owned by the seller, as they stand or after buildings have been erected for the seller’s own use, even if the seller makes multiple disposals.
Disposals under the first and second paragraphs are not professional trading unless the Authority establishes that they were made professionally with the intention of trading and making a profit under Article (19), item (7). The total disposal value is that stated in the disposal contract. The Authority bears the burden of proof if it does not accept that value.
Contribution of property in kind to the capital of a joint-stock company is excluded, provided the corresponding shares are not disposed of for five years. The disposer shall pay the tax within sixty days of disposal. The late-payment charge under Article (110) applies from the following day after that period expires.
For this Article, taxable disposal includes disposal by sale, bequest, donation or gift to persons other than ascendants, spouses or descendants; granting a usufruct over the property; or leasing it for more than fifty years.
Compulsory sales, whether administrative or judicial, and expropriation for public benefit or improvement are not taxable disposals. Donations or gifts to the Government, local administration units, public legal persons or public-benefit projects are also excluded. Tax paid under this Article shall be deducted from the taxpayer’s total tax liability where Article (19), item (7), applies.
Chapter Three – Exemption from Tax
Article (43)
[Repealed by Article 2 of the Real Estate Tax Law No. 196 of 2008.]
Chapter Four – Miscellaneous Provisions
Article (44)
[Repealed by Article 2 of the Real Estate Tax Law No. 196 of 2008.]
Article (45)
The taxpayer shall deduct the amount paid for real estate taxes from the taxable base due under the provisions of Chapter Five of the Second Book of this law, provided that the deduction does not exceed the amount of such tax.
Article (46)
Article (39) shall not apply to built properties forming part of the assets of an establishment or company.
Part Six – Dividend Distributions
Chapter One – Taxable Revenues
Article (46 Bis)
Tax shall apply to dividend distributions on shares and equity interests received by a natural person resident in Egypt from corporations or partnerships, including companies established under the special economic zone regimes, with the exception of distributions made in the form of bonus shares, regardless of whether such distributions are realised inside or outside Egypt and regardless of the form in which the distribution is made. For the purposes of this Article, civil companies shall be treated as partnerships. The tax shall also apply to profits, returns, and investment distributions received by unit holders in the following investment vehicles established in accordance with the Capital Market Law No. 95 of 1992:
• Debt instrument investment fund
• Venture capital funds and companies
• Equity investment fund
• Real estate investment funds
• Holding funds
Chapter Two – Determination of Taxable Distributions
Article (46 Bis 1)
The taxable base for dividend distributions stipulated in Article (46 bis) shall be determined with respect to the amounts received by the resident natural person in accordance with what is determined by the competent distributing authority. This taxable base shall include, in the case of a resident natural person engaged in an activity subject to tax pursuant to the provisions of Part Three of Book Two of the Law, the full amount of dividend distributions received by such person, whether from sources within Egypt or abroad.
Chapter Three – Tax Rate and Collection
Article (46 Bis 2)
Notwithstanding the provisions of Article (8) of this Law, the tax rate on dividend distributions stipulated in Article (46) Bis of this Law, realized from sources within Egypt during the year in which they are received by a resident natural person, shall be ten percent (10%) without deduction of any expenses. This rate shall be reduced to five percent (5%) if the securities are listed on the Egyptian Exchange. The tax rate on profits, yields, and investment distributions received by certificate holders in investment funds in debt instruments, venture capital funds and companies, equity investment funds, real estate investment funds, and holding funds established pursuant to the Capital Market Law referred to herein shall be fifteen percent (15%) for juridical persons and five percent (5%) for natural persons. The entities responsible for executing these transactions shall withhold the tax and remit it to the Central Department for Deduction and Collection on Account of Tax within the Authority no later than five working days from the beginning of the month following the month in which the tax was collected, using the prescribed form.
Part Seven – Profits from the Sale of Shares and Securities
Chapter One – Taxable Income
Article (46 Bis 3)
The tax applies to capital gains realized from the disposal of quotas in companies or securities not listed on the Egyptian Stock Exchange, whether these gains are realized in Egypt or abroad. Where the disposer of the unlisted securities or the quotas is a non-resident, he is obligated to compute and remit the tax on the realized capital gains within sixty days from the date of the transaction, in accordance with the procedures specified by the Executive Regulations of this Law. This tax does not apply to capital gains realized by a non-resident from the disposal of Treasury bills.
Chapter Two – Determination of Taxable Income
Article (46 Bis 4)
The taxable capital gains realized from the disposal of securities not listed on the Egyptian Exchange, or of quotas, are determined on the basis of the difference between the price of sale, exchange, or any form of disposal of these securities or quotas and the cost of their acquisition, after deducting the brokerage commission. Where the price of sale, exchange, or disposal is at fair value, there is added to the cost of acquisition an amount equal to the credit-and-discount rate announced by the Central Bank for each year of holding, provided that these securities or quotas are not disposed of before the lapse of three years; and the cost of acquisition is computed on the basis of the weighted average, all in accordance with what is specified by the Executive Regulations of this Law.
Chapter Three – Tax Rate and Method of Collection
Article (46 BIS 5)
[Repealed by Article 6 of Law No. 151 of 2026.]
Chapter Four – Avoidance of Double Taxation
Article (46 Bis 6)
Taxes paid abroad on income derived from the sources specified in Articles (17), (19), (32), (46 bis), and (46 bis 3) of this Law and received by a resident natural person from outside Egypt shall be deductible from the tax due on such income under the provisions of Chapters Three and Four of Book Two of this Law, and within the limit of the tax calculated. Distributions received by a resident natural person from resident legal entities shall be excluded from the taxable income base of that person, after deducting the related costs, in accordance with the provisions of the Executive Regulations. For the purposes of applying the first paragraph of this Article, the “calculated tax” shall mean the portion of tax due on the taxable base under the provisions of Chapters Three and Four corresponding to the income referred to, as determined by the Executive Regulations. Losses incurred abroad may not be deducted from the tax base in Egypt for the same tax period or any subsequent period. Furthermore, it is not permitted to offset profits realized abroad in one country against losses incurred in another country.
Article (46 Bis 7)
[Repealed by Article 6 of Law No. 151 of 2026.]
Book Three – Tax on Profits of Corporate Bodies
Article (47)
An annual tax shall be imposed on the total net profits of legal persons, regardless of their purpose. The tax shall apply to:
1. Legal persons resident in Egypt, in respect of all profits they realise, whether in Egypt or abroad, except the National Service Projects Organization of the Ministry of Defence.
• Corporate bodies not resident in Egypt with regards to profits realized through permanent establishment in Egypt.
Article (48)
In application of article (47) of the present law, the following shall be corporate body:
1. Capital companies and partnerships, regardless of the law to which they are subject, and de facto companies.
• Cooperative societies and their unions taking into consideration exemptions prescribed thereto by law.
• Public organizations and other public corporate bodies with regards to the taxable activity practiced without prejudice to exemptions prescribed by laws governing their establishment.
• Foreign banks, companies and establishments even though its head office is abroad and branches in Egypt.
• Units established by the municipal department with respect to taxable activity.
Article (49)
The tax base shall be rounded down to the nearest ten Egyptian pounds and taxed at a rate of 22.5% of annual net profits. As an exception to this rate, the profits of the Suez Canal Authority, the Egyptian General Petroleum Corporation and the Central Bank shall be taxed at 40%, and the profits of companies engaged in the exploration for and production of oil and gas shall be taxed at 40.55%.
Article (49 Bis)
[Repealed by Article 6 of Law No. 151 of 2026.]
Article (50)
The following are Exempt from Tax:
• Ministries and government agencies.
• [Repealed].
• Non-governmental associations and institutions established pursuant to the provisions of the law regulating civil work, limited to the purpose for which they were established.
• Entities that are non-profit and engage in activities of a social, scientific, sports, or cultural nature, limited to activities that are not commercial, industrial, or professional.
• Profits of private insurance funds subject to the provisions of the Private Insurance Funds Law promulgated by Law No. 54 of 1975.
• International organizations, technical cooperation agencies, and their representatives, provided that an international agreement stipulates their exemption.
7. Returns on non-governmental bonds listed on the Egyptian stock exchanges, and capital gains realised from the disposal of securities listed on the Egyptian Stock Exchange, without deducting losses arising from such disposal. This exemption shall not apply to capital gains from the disposal of securities listed on the Egyptian Stock Exchange where the disposal results in the delisting of the company’s shares.
• [Repealed].
• Returns obtained by legal persons on securities and deposit certificates issued by the Central Bank of Egypt or revenues derived from dealings therein, as an exception to the provisions of Article (56) of this Law.
10. Dividend distributions received by a parent or holding company from resident or non-resident subsidiaries, subject to the following conditions: (a) the parent or holding company holds at least 25% of the subsidiary’s capital or voting rights; and (b) it has held that percentage for at least two years, or undertakes to retain it for two years from the date of acquiring the shares or voting rights.
• Profits of land reclamation or cultivation companies for ten years from the commencement of activity or production, as applicable, according to rules set by the executive regulations of this Law.
• Profits of poultry production companies, beekeeping, livestock breeding and fattening farms, and fisheries and fish farms companies, for ten years from the commencement of activity.
• Capital gains resulting from settlements on debts of public business sector companies or companies in which the state owns not less than 51% of their capital, as part of debt settlements with banks and other creditors, in exchange for transferring ownership of all or some of their lands; exemption applies in proportion to the state’s ownership in the capital of such companies.
• Profits of debt instrument investment funds and holding investment funds in the same instruments or investment funds established under the Capital Market Law mentioned above, within the scope of their licensed purpose, as well as investment returns obtained by certificate holders in these funds, provided that the fund’s investments in bank deposits do not exceed 10% of the average total annual investments, without prejudice to the provisions of Article (58) of this Law.
15. Profits of investment funds investing in shares listed on the Egyptian Stock Exchange, and profits of holding investment funds investing in the same shares or in funds investing in those shares, established under the aforementioned Capital Market Law; dividends and capital gains received by those funds; returns on their bank deposits; and returns received by holding investment funds from the funds in which they invest. This exemption is conditional upon the share portfolio being limited to shares of companies listed on the Egyptian Stock Exchange, is without prejudice to Article (58) of this Law, and applies within the scope of the funds’ licensed purpose.
• Profits of venture capital funds and companies established under the aforementioned Capital Market Law, within the scope of their licensed purpose, including distributions, capital gains, and returns on their bank deposits, provided that: o The percentage of investments in resident and non-listed start-up companies on the Egyptian Exchange is not less than 80% of total investments at the end of the investment allocation period specified in the information memorandum or prospectus, as applicable. o The leverage ratio from debt does not exceed 20% of total investments. This exemption does not apply to any revenues or profits of these funds and companies from other sources, without prejudice to the provisions of Article (58) of this Law.
• Profits of charitable investment funds established under the aforementioned Capital Market Law, within the scope of their licensed purpose, including distributions, capital gains, and returns on their bank deposits, provided that investment returns are used for the charitable activities for which the funds were established, without prejudice to Article (58) of this Law.
• Profits of real estate investment funds established under the aforementioned Capital Market Law, within the scope of their licensed purpose, including real estate wealth revenues, distributions, capital gains, and returns on their bank deposits, provided that: o The fund invests at least 80% of the average total annual investments in shares of companies or real estate funds, or built properties. o At least 80% of the fund’s revenues derive from leasing income of real estate assets, dividends from shares of real estate companies, capital gains from the sale of fixed assets or shares of real estate companies, and investment returns, distributions, and profits obtained from other real estate funds. o The fund does not engage in real estate development or contracting activities. All without prejudice to the provisions of Article (58) of this Law. In applying the provisions of paragraphs (14, 15, 16, 17, and 18) of this Article, amounts obtained by a resident natural or legal person holding certificates shall be excluded from the taxable base of that person after deducting related expenses, according to what is determined by the executive regulations of this Law. It is not permissible for the deduction of any tax exemption stipulated in this Law or any other law to result in carrying forward losses to subsequent years.
Part Two – Determining Taxable Income
Article (51)
Net taxable income shall be determined as per provisions applied to profits of the commercial and industrial activity provided for in part 3 of book (2) of the present law and in cases where no specific provision has been included in this chapter.
Article (52)
The following shall not be deductible costs: 1. Interest paid by the legal persons specified in Article (47) of this Law on loans and advances obtained in excess of twice average equity, according to financial statements prepared in accordance with Egyptian Accounting Standards. The rule in this Article shall instead apply to interest on loans and advances exceeding four times average equity, according to such financial statements, if the following conditions are satisfied: (a) the legal person implements national infrastructure projects designated by a decision of the Prime Minister upon the Minister’s proposal; (b) the loans and advances are obtained from unrelated parties; and (c) the legal person’s participation in the national projects is at least 25% of the total value of its investments. Eligibility for the preceding paragraph ends upon expiry of the term of the loans relating to the execution of the basic works of the national project in which the legal person participates. This item does not apply to banks, insurance companies or companies carrying on financing activity designated by a decision of the Minister. 2. Amounts set aside to create or replenish provisions of any kind, except: (a) 80% of loan provisions that banks are required to create under the Central Bank’s rules for preparing and presenting financial statements and valuation bases; and (b) technical provisions that insurance companies are required to create under the Law on Insurance Supervision and Control in Egypt promulgated by Law No. 10 of 1981. 3. Profit shares, distributed dividends and attendance fees paid to shareholders for attending general meetings. 4. Membership remuneration and allowances received by chairpersons and members of boards of directors. 5. Employees’ share of profits whose distribution is decided in accordance with the law. 6. The other costs specified in Article (24) of this Law.
Article (53)
Capital gains arising from the revaluation of assets shall be subject to tax in the event of a change in the legal form of a legal entity. The legal entity shall be entitled to defer the tax liability provided that it records the assets and liabilities at their book values at the time of the legal form change for tax calculation purposes, and that depreciation on assets and the carrying forward of provisions and reserves are computed in accordance with the rules established prior to such change. The following shall be considered, among others, as changes in the legal form of a legal entity:
• The merger of two or more resident companies.
• The division of a resident company into two or more resident companies.
• The transformation of a partnership into a corporate company or the transformation of one corporate company into another.
• The transformation of a legal entity into a corporate company. The deferral of tax liability shall be conditional upon no disposal of the shares or interests resulting from the legal form change occurring within three years from the date of such change. The deferred tax shall become payable if another change in the legal form of the legal entity occurs or if the legal entity is dissolved for any reason.
Article (54)
The foreign tax paid by a resident company for its profits achieved abroad shall be deducted from the tax due thereon according to this law provided the supporting documents must be made available. The losses incurred abroad shall not be deducted from the taxable income in Egypt for the same taxation period or any other following period. The deduction mentioned in the first paragraph must not exceed the tax payable in Egypt which could have been payable on the profits gained from works carried out abroad.
Article (55)
The provision of art. (29) Shall not apply to losses incurred by the company in the taxation period and prior periods if a change occurred in its ownership at a percentage exceeding 50% of shares or quotas or in voting rights, provided such change should be accompanied by a change in the activity. In order for the preceding paragraph to be applicable to the joint stock companies and partnership limited by shares, the shares must not be offered for negotiation in the Egyptian stock of exchange
Book Four – Withholding Tax
Article (56)
There shall be subject to tax at the rate of 20%, without deducting any costs therefrom, the amounts paid by owners of sole proprietorships, legal persons resident in Egypt, and non-resident entities that have a permanent establishment in Egypt, to non-residents in Egypt. These amounts include: 1- Interest (returns). 2- Royalties. 3- Consideration for services; and the permanent establishment’s share of the administrative, control and supervision expenses borne by its head office abroad shall not be regarded as consideration for services. Upon determining the profits of the permanent establishment, that which is taken into account within such head-office expenses must not exceed 10% of the net taxable profit of the establishment, must not include any royalties, interest, commissions or direct wages, and requires a certified and authenticated certificate from the head office’s auditor. 4- Consideration for the activity of a sportsperson or artist, whether paid to him directly or through any entity. There shall be exempt from this tax the interest on loans and credit facilities obtained by the government, local administration units, and other public legal persons from sources outside Egypt. Likewise exempt is the interest on loans or facilities obtained by public-sector companies, public-business-sector companies, and the private sector from unrelated persons for the purposes of financing the implementation of national infrastructure projects designated by a decision of the Prime Minister upon the Minister’s proposal, on the following conditions: 1- that the term of the loan or facility be not less than five years; and 2- that the company’s participation in the national projects be not less than (25%) of the total value of its investments. In all cases, the benefit of this exemption ceases upon the expiry of the term of the loans and facilities relating to the execution of the basic works of the national project in which the company participates. The establishments, persons and entities referred to in the first paragraph — including companies, establishments and branches set up under the Law on Economic Zones of a Special Nature, and projects set up under the Free Zones system — shall withhold the tax due and remit it to the Authority on the first working day following the day of withholding.
Article (56 Bis)
There shall be subject to tax at the rate of (10%), without deducting any costs, the dividends distributed by capital companies or partnerships — including companies set up under the system of the Economic Zones of a Special Nature — to a non-resident natural person and to a resident or non-resident legal person, including the profits of non-resident legal persons realized through a permanent establishment in Egypt, except for distributions made in the form of bonus shares; and the rate of this tax shall be (5%) of the dividends if the securities are listed on the Egyptian Stock Exchange. In applying this Article, civil companies shall be treated as partnerships. The profits of non-resident legal persons realized through a permanent establishment in Egypt shall be deemed distributed by operation of law within sixty days from the close of the financial year of the permanent establishment. The dividends obtained by resident legal persons from the profits of other resident legal persons, and the corresponding cost, shall be excluded from the tax base on the profits of legal persons provided for in Book Three of this Law, in accordance with the Executive Regulations. Likewise, the distributions obtained by a resident company from the distributions made by another resident company shall be excluded from the base of the distributions tax. The entities carrying out the transaction shall withhold the tax and remit it to the Central Department for Deduction and Collection on Account of Tax within at most five working days from the beginning of the month following the month of collection, on the prescribed form.
Article (57)
Tax shall apply to the amounts paid by individual firms and corporate bodies to any natural persons as commission or brokerage if not related directly to his profession. The payer of commission or brokerage shall have to retain the tax accrued and remit it to the tax inspectorate within the first fifteen days of the month following the month wherein the commission or the brokerage has been paid according to the rate stipulated in article (56) of the present law without deducting any costs.
Article (58)
Without prejudice to any tax exemptions stipulated in other laws, the yields on bonds issued by the Ministry of Finance in favor of the Central Bank or other banks shall be subject to tax at a rate of 32%, without deduction of any expenses. The payer of such yields or the recipient thereof is obliged to withhold the due tax at the time of payment and remit it to the competent Tax Authority no later than the first business day following the payment. The yields on Treasury bills, and the yields paid to entities holding credit balances in the Unified Treasury Account, shall be subject to tax at a rate of 20%, without deduction of any expenses. The payer of these yields is obliged to collect the due tax and remit it to the competent Tax Authority on the day following the day of withholding. Similarly, the yields on Treasury bonds shall be subject to the same tax rate of 20%, and the payer is required to withhold the tax amount and remit it to the competent Tax Authority no later than the first business day following the day on which the tax was withheld. The yields referred to in the foregoing paragraphs shall be treated as a separate tax base distinct from other taxable revenues. The costs related to these yields shall not be considered as deductible expenses for the purpose of calculating the tax due on other revenues, in accordance with the provisions set forth in the Executive Regulations of this law.
Book Five – Deduction, Collection and Advance Payments on Account of Tax
Part One – Commercial & Industrial Activity
Article (59)
The entities and establishments listed hereinafter shall withhold a percentage from every amount exceeding three hundred Egyptian pounds paid as commission, brokerage, or in consideration for purchase, supply, contracting, or service to any person in the private sector, as well as on all dividends distributed by capital companies regardless of their amount. The Minister shall issue a decision specifying this percentage, which shall not exceed five percent (5%) of such amount, as an advance payment on the tax due by those persons. Insurance premiums paid to insurance companies are excluded. The entities and establishments required to withhold are:
• Government ministries and their agencies, local administrative units, public authorities, national economic or service authorities, public sector companies and units, public business sector companies, capital companies, establishments and companies subject to investment laws, partnerships whose capital exceeds fifty thousand Egyptian pounds regardless of their legal form, companies established under special laws, companies and projects established within free zones, branches of foreign companies, pharmaceutical warehouses and import offices, cooperative societies, press institutions, educational institutes, professional unions, associations, clubs, youth centers, federations, hospitals, hotels, non-profit associations and institutions regardless of their purposes, professional offices, foreign representation offices, cinematic production establishments, theaters, entertainment venues, and private insurance funds established under Law No. 54 of 1975 or any other law.
• Other entities and establishments as determined by a decision issued by the Minister. These entities and establishments shall remit the amounts withheld to the Tax Authority in accordance with the procedures set forth in the Executive Regulations of this law. Any entity or establishment that fails to withhold or remit such amounts shall be liable to pay these amounts to the Tax Authority along with any applicable late payment penalties. In all cases, the entities and establishments referred to in paragraphs (1) and (2) of the first clause of this article are obligated to notify the Tax Authority of a statement of transactions and amounts paid to any person in the private sector, if the value of transactions during each quarterly period exceeds three hundred Egyptian pounds. Such notification shall be submitted no later than the end of April, July, October, and January each year, covering the transactions of the preceding months, in accordance with the procedures determined by the Executive Regulations of this law.
Article (59 Bis)
The entities specified in item (1) of the first paragraph of Article (59) of this Law, which undertake the sale or distribution of any industrial goods, products, or locally produced or imported agricultural commodities to private sector persons for trading or manufacturing purposes, shall notify the Tax Authority with a detailed statement of the transactions and amounts received from such persons.
Article (59 Bis 1)
The entities provided for in items (1) and (2) of the first paragraph of Article (59) of this Law shall notify the Authority with a statement of the dealings, amounts, and rents that they collect from the tenants of the places owned by them and designated for trading or manufacturing therein, or for the provision or preparation of any services, foodstuffs, or beverages.
Article (59 Bis 2)
The Minister shall issue a decision specifying the goods, industrial products, agricultural commodities, types of activities, and categories of leases to which the provisions of Articles (59 bis) and (59 bis 1) of this Law apply. The entities and establishments referred to in items (1) and (2) of the first paragraph of Article (59) of this Law are obligated to notify the Tax Authority with a statement detailing the value of the goods, industrial products, agricultural commodities, transactions, amounts, and leases received from each taxpayer. Such notification shall be submitted no later than the end of April, July, October, and January of each year, covering the preceding three months, in accordance with the procedures determined by the Executive Regulations.
Article (59 Bis 3)
[Repealed by Article 4 of Law No. 53 of 2014.]
Article (60)
Private sector persons referred to in article (59) of the present law shall not be subject to provisions requiring deduction on account of tax if the tax department become ascertain of the company having regular registry on which basis the company pays the quarterly down payments according to provisions of the second chapter of this part.
Chapter Two – Down Payments
Article (61)
Subject to Article (63), the advance payment system, for the purposes of this Law, means the taxpayer’s payment of an amount on account of tax due for the tax period equal to 60% of either of the following:
1. The amount of tax most recently declared by the taxpayer.
• Tax estimated for the taxation year he wishes to apply payments system to, if the taxpayer has never submitted tax return or the tax return submitted for the taxation period preceding his submission of the application includes losses.
Article (62)
Taxpayer shall have to choose either the system of deduction an account of tax as per article (59) of the present law or to comply with the down payments system stipulated in this chapter. Choice shall be made through an application submitted by the taxpayer to the competent tax inspectorate 60 days at least before the starting of the taxation period to which he likes to apply down payments system. The tax authority shall have to reply the request of the taxpayer within 60 days from the date of submitting his request. If the taxpayer has not received a notice within such period, it shall mean rejection of the request. The executive regulation of this law specifies the form of the application and the accompanying documents and the procedures to be followed to notify the taxpayer of the tax authority decision.
Article (63)
The taxpayer, pursuant to the advance payment system, shall pay the percentage stipulated in Article 61 of this Law in three equal installments, each installment to be paid successively no later than June 30, September 30, and December 31 of each year. After making the second installment payment, the taxpayer may notify the Tax Authority to reduce or waive the third installment if it becomes evident that the full- year profits will be lower than the estimated profits for the preceding year. The number of installments may be reduced when the remaining period after submitting the request referred to in Article 61 is less than twelve months, provided that each installment is paid to the competent Tax Office in accordance with the conditions, procedures, and forms specified by the Executive Regulations of this Law. The amounts paid under this system shall be settled upon submission of the annual tax return stipulated in Article 31(c) of the Unified Tax Procedures Law. The taxpayer shall pay the remaining tax due according to the return after deducting the advance payments already made together with an annual return added to those advance payments, calculated at the credit and discount rate announced by the Central Bank, disregarding fractions of a month or an Egyptian pound.
Article (64)
The taxpayer may amend the system of down payments he has chosen and to comply with the system of deduction on account of tax as per article (59) of the present law, provided the following requirements are satisfied:
• Down Payments system has been applied within one full year at least and has paid all dues prescribed under this system.
• Submission of an application by the taxpayer to the competent tax inspectorate within 90 days at least prior to the beginning of the taxation year he wishes to change payments system there from. The tax authority shall approve the as long as the two foregoing requirements have been fulfilled provided, the taxpayer be notified of the resolution of the tax authority within 60 days from the date of submitting the application, otherwise the application shall be deemed accepted if the taxpayer didn’t receive a reply. The executive regulation specifies the procedures for submitting the application and notifying the taxpayer.
Article (65)
The taxpayer shall be exempted from the application of down payments system in any of the following two cases:
• Incurring tax loss by the tax payer for two consecutive years.
• Changing the legal form of the company or the establishment. The Tax Authority may deny the taxpayer the use of this system if significant differences have been found between the estimated profits of the taxpayer and his actual profits that have been subjected to tax in each year of application, in such case, the Tax Authority shall have to notify the taxpayer of this by return receipt letter.
Chapter Three – Collection on Account of Tax
Article (66)
Authorities that grant licences for wholesale trading in vegetables, fruit, cereals or other foodstuffs, or for practising craft activities, shall, when renewing a licence, collect an amount on account of tax from the person in whose name the licence is renewed. They shall not renew the licence before collecting that amount. The Minister shall determine the amount by decision, up to 10% of the renewal fee.
Article (67)
Customs Authority shall have to collect from private sector persons percentage of the amount of their imports allowed for trading and manufacturing purposes in the country on account of tax due from them. In case of transferring such goods or the endorsement of their documents to other, a percentage shall be collected from the transferor and the transferee as well as parties to the endorsement. A ministerial decree shall have to be issued for the determination of such percentage at a maximum of 2% of the value of imports; such percentage shall be collected in conjunction with customs duty prescribed on such goods following the same collection procedures.
Article (68)
Slaughter – houses upon slaughtering for the account of private sector taxable persons shall have to collect an amount on account of tax besides the slaughtering fees for each slaughtered head and such amount shall be determined by a resolution issued by minister of finance without exceeding 10% of slaughtering fees.
Article (69)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Part Two – Non-Commercial Professions
Article (70)
The entities specified in Article (59) of this Law shall deduct, on account of tax, 5% from each amount exceeding one hundred Egyptian pounds paid to practitioners of the non-commercial professions designated by a decision of the Minister.
Chapter Two – Collection on Account of Tax
Article (71)
The registries of courts of all levels shall, upon the filing of statements of claim or appeals for registration, and the real estate registration offices shall, upon marking documents as suitable for registration, collect an amount on account of tax due from the lawyer signing the statement or document. Each hospital shall collect an amount on account of tax from any doctor or specialist who performs work there for their own account. The Customs Authority shall collect from each person practising customs clearance an amount for every customs declaration submitted to it, on account of the tax due. The Minister shall determine the amounts referred to in the preceding paragraphs by decision.
Part Three – General Provision
Article (72)
Departments stipulated in article 66, 67, 68, 69, 70 and 71 of the present law shall have to remit the amounts collected on account of tax-to-Tax Authority as per procedures and on the dates set out in the executive regulation. Should such departments fail to deduct or to remit the deductible amounts to tax authority, such amounts shall be paid to the tax authority by the said department in addition to delay fine.
Article (72 Bis)
Non-primary employers shall withhold a percentage of (10%) on account from the amounts paid to resident individuals and remit it to the competent tax authority within the first fifteen days of each month. They are obligated to notify the primary employer and the Tax Authority of the amounts received by the individual and the tax withheld. The primary employer shall be responsible for calculating and settling the tax in accordance with Article (8) of this Law. The Executive Regulations of this Law shall determine the rules and procedures for withholding and settlement.
Article (73)
The provisions relating to withholding and collection on account of tax shall not apply to the taxpayer during the period of exemption or non-liability to tax, except for the obligations stipulated in Articles (59), (59 bis), (59 bis 1), and (59 bis 2) of this Law.
Book Six – Liabilities of Tax Payers & Other
Part One – Notification & Bookkeeping
Article (74)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (75)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (76)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (77)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (78)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (79)
If the taxpayer ceases operations either wholly or partially, the actual profits up to the date of cessation shall be included in the tax base. Partial cessation means the termination by the taxpayer of certain types of activities or the closure of one or more branches where the activity is conducted. The taxpayer must notify the competent tax authority within thirty (30) days from the date of cessation; otherwise, the profits shall be calculated for a full tax year unless the taxpayer proves that no revenues were generated after that date.
Article (80)
In the event of the transfer of all or part of an establishment, the transferor shall notify the competent tax authority of such transfer within thirty (30) days from the date of occurrence; otherwise, the profits shall be assessed for a full tax year. The transferor and the transferee shall be jointly and severally liable for all taxes due on the profits of the transferred establishment up to the date of transfer, as well as for any taxes due on the capital gains arising from such transfer. The transferee may request from the competent tax authority a statement of the taxes payable in respect of the transferred establishment. The tax authority shall provide the requested statement by registered mail with acknowledgment of receipt within ninety (90) days from the date of the request; otherwise, the transferee shall be discharged from the requested tax liability, and their responsibility shall be limited to the amounts stated in the said statement. The transfer shall have no effect with respect to the collection of taxes unless the legally prescribed procedures concerning the sale and mortgage of commercial premises are duly followed. The tax due on the profits of the transferred establishment up to the date of transfer shall be determined, and the transferee shall have the right to appeal the tax for which they are liable.
Article (81)
A taxpayer who wishes to cease activity, transfer the establishment or leave the country permanently may request the Authority to determine the taxpayer’s tax position up to the date of cessation, transfer or departure, provided that the taxpayer has filed the returns required under this Law and pays the fee determined by the Executive Regulations, which shall not exceed twenty Egyptian pounds. The Authority shall grant the request within ninety days of receiving it.
Part Two – Tax Returns
Article (82)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (83)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (84)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (85)
If, at least fifteen days before the expiry of the period prescribed for filing the return, the taxpayer requests an extension and, on the date of the request, pays the tax according to the estimate stated in that request, the filing deadline shall be extended by sixty days. That extension shall not affect the tax payment deadline or the date from which late-payment interest accrues on any unpaid amount.
Article (86)
The entities obligated to apply the withholding provisions shall pay the collected amounts by the end of April, July, October and January of each year at the latest, and shall maintain the records necessary for examination by the Authority, provided that such records include the following data for each tax period: (a) all transactions and the persons dealt with under the withholding system; (b) the amount collected on account of tax. Such entities shall send a copy of the said records to the Authority for retention, in accordance with the rules and procedures determined by the Executive Regulations.
Article (87)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (87 Bis)
The taxpayer shall be obligated to pay an additional amount of tax equal to twenty percent (20%) of the difference between the final tax amount and the tax amount declared in the tax return if such difference is less than fifty percent (50%) of the final tax amount; and an amount equal to forty percent (40%) of the difference between the final tax amount and the tax amount declared in the tax return if such difference equals or exceeds fifty percent (50%) of the final tax amount; and an amount equal to forty percent (40%) of the final tax amount in the event of failure to submit the tax return. This shall apply only if the final tax amount is determined after exhaustion of the ordinary appeal procedures. These percentages shall be reduced by half in the case of an agreement between the taxpayer and the tax authority before referral or recourse to the Appeal Committee.
Article (88)
Tax authority may not disapprove the regular books & records of the taxpayer according to article (78) of the present law or disregard them unless the tax authority has proved the incorrectness of such books based on supporting documents.
Part Three – Tax Assessment
Article (89)
Tax shall be assessed on the profits established by the return filed by the taxpayer. The return shall constitute a tax assessment and an obligation to pay by the statutory deadline, and the tax shall be paid according to that return.
Article (90)
The tax authority may amend the assessment as per the data included in the tax return and the documents according thereto. The tax authority may also make an estimated tax assessment in light of any available data if the taxpayer has not submitted his tax return or the documents supporting thereto. If certain documents have been made available to the tax authority proving the inconsistency of the tax return with reality, the tax authority shall notify the taxpayer, make the inspection. Rectify the tax return or amend it and determine the taxable revenues. The chairman of the tax authority may, after the approval of minister of finance, make assessment of the tax before its accrual date to be collected if specific evidence has been revealed that the taxpayer is planning for tax evasion or for transferring his assets to another person or taking other measures adverse to the process of collecting tax. The competent tax authority in such case shall have to notify the taxpayer by a return receipt letter of the elements of tax assessment and its amount on the form indicated in the executive regulation of this law
Article (91)
The taxpayer has the right to request a refund of amounts overpaid as tax credits within five years from the date the right to the refund arises.
Article (92)
If tax is assessed on a person and it is established that the person acts for another person through simulation or collusion to obtain an advantage or evade an obligation imposed by this Law, both persons shall be jointly and severally liable for the tax due on the profits.
Article (92 Bis)
When determining the tax assessment, the tax effect of any transaction shall not be considered if the main purpose or one of the main purposes of completing such transaction is tax avoidance, whether by eliminating or deferring the tax liability. This applies regardless of whether the transaction is conducted in the form of a deal, agreement, promise, or otherwise, and whether it occurs in a single stage or multiple stages. The decisive factor in tax assessment shall be the true economic substance of the transaction. The main purpose or one of the purposes of the transaction is deemed to be tax avoidance especially in the following cases:
• If the expected profit before tax is negligible compared to the value of the anticipated tax benefits from the transaction.
• If the transaction results in significant tax exemptions that do not reflect the risks borne by the taxpayer or its cash flows due to the transaction.
• If the transaction includes elements that have contradictory effects or that cancel each other out. In all cases, the burden of proof lies with the tax authority to demonstrate that the main purpose or one of the main purposes is tax avoidance. The taxpayer may provide evidence that there are no tax reasons behind their choice or execution of the transaction. A committee shall be formed by a ministerial decision, chaired by the head of the tax authority or their delegate, to consider cases of tax avoidance. The taxpayer shall not be notified of the existence of any tax avoidance case against them except after the committee’s approval.
Article (93)
In all cases, the Authority shall, on its own initiative or at the taxpayer’s request, correct clerical and arithmetic errors.
Part Four – Inspection and Investigations
Article (94)
The Authority shall annually audit taxpayers’ returns through a sample determined by rules and criteria issued by a decision of the Minister upon the recommendation of the Head of the Authority. The provisions of this article shall not apply to taxpayers who do not maintain regular books and accounts in accordance with the provisions of Article (78) of the Income Tax Law.
Article (95)
No re-examination of previously audited items shall be permitted unless substantive new facts emerge that necessitate a re-examination.
Article (96)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (97)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (98)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (99)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (100)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (101)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Part Five – Collection Guarantees
Article (102)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (103)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (104)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (105)
Tax shall be collected in a single payment or in instalments not exceeding the number of tax years for which it became due. If general circumstances or circumstances specific to the taxpayer prevent collection on that basis, the Head of the Authority or their delegate may allow instalments over a longer period not exceeding twice the number of tax years. Entitlement to instalment payment shall lapse if any instalment is paid late. At the taxpayer’s request, the Head of the Authority or their delegate may approve renewal of the instalment arrangement in cases they consider appropriate.
Article (106)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (107)
[Repealed by Article 4 of the promulgating provisions of Law No. 206 of 2020.]
Article (108)
[Repealed by Law No. 206 of 2020 (Unified Tax Procedures Law).]
Article (109)
Any public body or private sector person who has retained amount on account of tax authority or has remitted such amounts in application of this law or law no.308 of 1955 referred to shall have to give the tax payer (upon his request) a certificate exempted from all dues stated therein amounts retained, date of retention and date of remitting such amounts to tax authority. Such certificates or receipts issued by parties that have affected deduction or collection on account of the tax due from tax payer shall be deemed as documents evidencing payment of such tax within the amounts stated therein even if the retainer has not remitted the amounts retained to tax authority.
Article (110)
Late Payment Interest Shall Be Payable On:
• Any amount exceeding two hundred Egyptian pounds (EGP 200) that remains unpaid from the tax due, even in cases where an installment plan has been granted, calculated from the day following the deadline for filing the tax return.
• Any taxes or amounts not remitted that are legally required to be withheld at source or collected and remitted to the public treasury, calculated from the day following the expiration of the statutory remittance period under the provisions of this Law. The late payment interest referred to in this Article shall be calculated based on the Central Bank of Egypt’s declared discount and credit rate on the January 1 preceding that date, plus 2%, with fractional months and Egyptian pounds disregarded. Filing an objection or legal appeal shall not suspend the accrual of this interest. If the Tax Authority amends the taxpayer’s return after the lapse of three years from the end of the period allowed for filing the return, no interest shall be charged for the period following the end of those three years until the taxpayer is notified of the amendment. Interest shall resume accruing from the date of such notification. In the event of an appeal against the Authority’s amendment decision, the interest due shall be recalculated in accordance with:
• The agreement reached between the taxpayer and the Authority, or
• The determination of the appeal committee or court ruling regarding the payable tax. A 30% waiver of the accrued late payment interest shall be granted on unpaid taxes arising from a settlement agreement with the Authority reached before the issuance of the Tax Appeal Committee’s decision, provided the taxpayer pays the due tax amount in full.
Article (111)
The late-payment interest on the overdue amounts shall be treated in the same manner as the tax to which it relates. The order of satisfaction of the amounts paid to the Authority in fulfilment of the taxpayer’s obligations shall be as follows: 1- Administrative and judicial expenses. 2- Taxes withheld at source. 3- Taxes due. 4- The late-payment interest.
Article (112)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (113)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (114)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (115)
The Minister may issue tax certificates for subscription by taxpayers, bearing a tax-exempt return determined by the Minister. These certificates and their accrued returns shall discharge tax liabilities when used to pay the taxes due.
Part Six – Appeal Procedures
Article (116)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (117)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (118)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (119)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (120)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (121)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (122)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (123)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (124)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (125)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (126)
The Minister alone may issue general rules and instructions binding on the Authority when implementing this Law and its Executive Regulations.
Article (127)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (128)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (129)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (130)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Book Seven – Penalties
Article (131)
Without prejudice to any more severe penalty stipulated in the penal code or any other law, crimes indicated in the following articles shall be liable to penalties stipulated therein.
Article (132)
Shall be punished by imprisonment and by a fine of not less than ten thousand pounds and not exceeding one hundred thousand pounds, or by one of these two penalties, every accountant registered in the roll of accountants and auditors who has certified a tax return or supporting papers or documents, if he commits one of the following acts: 1- Concealing facts he came to know during the performance of his task which the documents whose correctness he attested did not disclose, where disclosing them was necessary for these accounts and documents to express the taxpayer’s true activity. 2- Concealing facts learned during the performance of his task relating to any amendment or change in the books, accounts, records or documents, where the effect would be to give a false impression of reduced profits or increased losses. In the case of recidivism, imprisonment and fine shall both be adjudged.
Article (133)
Every taxpayer who has evaded payment of the tax shall be punished by imprisonment for a period of not less than six months and not exceeding five years, and by a fine equal to the amount of the tax that was not paid pursuant to this Law, or by one of these two penalties. The taxpayer shall be deemed to have evaded payment by using one of the following methods: 1- Submitting the annual tax return in reliance on artificial books, records, accounts or documents while knowing this, or including therein data contrary to what is established in the books, records, accounts or documents which he has concealed. 2- Submitting the annual tax return on the basis that no books, records, accounts or documents exist, while including data contrary to what is established with him in books, records, accounts or documents which he has concealed. 3- The deliberate destruction of records or documents related to the tax before the expiry of the prescription period of the tax debt. 4- Fabricating or altering purchase or sale invoices or other documents to give the Authority a false impression of reduced profits or increased losses. 5- Concealing an activity, or part of it, that is subject to tax. In the case of recidivism, imprisonment and fine shall both be adjudged. In all cases, the offence of evading payment of the tax shall be deemed an offence prejudicial to honour and trustworthiness.
Article (134)
An accomplice shall be jointly and severally liable with the taxpayer for payment of the taxes evaded and the fines adjudged in respect of them.
Article (135)
Any person who fails to apply the system of tax withholding, deduction, collection, and remittance within the legally prescribed deadlines shall be subject to a fine equal to 25% of the unpaid amounts.
Article (135 Bis)
Any person who fails to notify the Tax Authority of the value of goods, industrial products, agricultural yields, transactions, amounts, and rents as stipulated under Articles (59), (59 bis), (59 bis 1), and (59 bis 2) of this Law shall be liable to a fine not less than ten thousand Egyptian pounds (EGP 10,000) and not exceeding fifty thousand Egyptian pounds (EGP 50,000). The minimum and maximum limits of the penalty shall be reduced by half if the required data is submitted before the Tax Authority’s right to claim the tax debt becomes time-barred by statute of limitations.
Article (136)
[Repealed — last legislative effect per the consolidated text: Article 4 of Law No. 101 of 2012.]
Article (137)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (138)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Book Eight – Final Provision
Article (139)
A Supreme Council for Taxation shall be established under the chairmanship of the Prime Minister, with its headquarters in Cairo. The Council shall aim to safeguard the rights of taxpayers across all tax types and to assist them in fulfilling their legal obligations under the tax laws and other related legislation. The Council shall be entrusted with the following responsibilities:
• Reviewing and approving the Taxpayers’ Rights Charter.
• Providing opinions on draft tax laws and their respective executive regulations.
• Conducting studies and submitting proposals aimed at enhancing the performance of tax authorities; the Ministry of Finance may also refer tax- related matters to the Council for deliberation.
• Receiving and reviewing complaints and grievances from taxpayers and other concerned parties, engaging with the relevant tax authorities to resolve them, and submitting a report thereon to the Cabinet.
• Providing legal and technical support to taxpayers and other eligible persons unable to afford representation, by engaging accountants and lawyers to advocate on their behalf before tax committees and courts.
• Assisting tax authorities in preparing tax manuals that educate taxpayers and stakeholders about their tax rights and obligations.
• Proposing mechanisms to address the issue of tax arrears across all types of taxes and customs duties.
• Coordinating with the Supreme Investment Council and the Ministry of Finance to promote the use of taxation as a tool to stimulate economic activity, regulate the relationship between investors and the state, review legislation, procedures, and tax/customs incentives, and assess investor tax compliance.
9. Continuously assessing tax administration projects and the extent to which they rely on a fair, actual basis for collecting all types of taxes and customs duties, and their measures to minimise tax appeals and disputes. The Council’s composition, any additional functions and its rules of procedure shall be determined by a Presidential Decree.
Article (140)
Repealed by Article 8 of Law No. 30 of 2023 Concerning the Amendment of Certain Provisions of the Income Tax Law.
Article (141)
Repealed by Article 8 of Law No. 30 of 2023 Concerning the Amendment of Certain Provisions of the Income Tax Law.
Article (142)
Repealed by Article 8 of Law No. 30 of 2023 Concerning the Amendment of Certain Provisions of the Income Tax Law.
Article (143)
Repealed by Article 8 of Law No. 30 of 2023 Concerning the Amendment of Certain Provisions of the Income Tax Law.
Article (144)
Repealed by Article 8 of Law No. 30 of 2023 Concerning the Amendment of Certain Provisions of the Income Tax Law.
Article (145)
Repealed by Article 8 of Law No. 30 of 2023 Concerning the Amendment of Certain Provisions of the Income Tax Law.
Article (146)
[Repealed by Law No. 30 of 2023.]
Article (147)
All funds and financial assets for which the right of their owners has been extinguished by the lapse of the statutory limitation period pursuant to a final and binding judgment shall devolve to the Public Treasury, provided such funds and assets fall within the following categories:
• Profits and returns generated from negotiable shares and bonds issued by any company, authority, or public or private entity.
• Shares, founders’ shares, bonds, and all other transferable securities related to the aforementioned companies, authorities, or entities.
• Deposits of securities, and in general, all entitlements arising from such securities held by banks or other institutions that accept such securities as deposits or for any other reason.
• Any amount paid by way of security, for any reason whatsoever, to any joint- stock company, authority, or public or private entity. All companies, banks, institutions, authorities, and other entities referred to in this Article shall be obligated to submit to the Authority, no later than the end of March each year, a report detailing all funds and financial assets subject to limitation during the preceding year and whose ownership has transferred to the State pursuant to the provisions of this Article. They shall also remit the aforementioned funds and assets to the Public Treasury within thirty (30) days of submitting such report.
Article (147 Bis)
Any person shall be exempted from the payment of all amounts of income tax due on their income, as well as from all amounts of general sales tax, regardless of the value of their capital, turnover, revenues, or annual net profit, in respect of all tax periods preceding the date on which this Law comes into force, irrespective of the number of such periods. The exemption shall also apply to all amounts associated with such taxes, including delay penalties, fines, additional taxes, and other related amounts, provided that the following two conditions are met: First: That the person has not previously been registered, submitted any tax return, or been subject to any form of tax audit or examination by the Egyptian Tax Authority (Income Tax – Sales Tax). Second: That the taxpayer submits an application to the competent tax office within twelve (12) months from the effective date of this Decree-Law requesting registration or the opening of a tax file and seeking the aforementioned tax exemption. Such application must include the following information:
• Name
• Activity
• Address
• Legal entity status
Article (148)
Repealed pursuant to Article 4 of Law No. 206 of 2020 regarding the issuance of the Unified Tax Procedures Law.
Article (149)
An individual taxpayer shall be entitled to an incentive not exceeding five percent (5%) of the annual tax due, in the event that they submit electronic invoices and receipts. The Minister shall issue the implementing rules and procedures governing this provision.
Translation source and editorial note
The source base comprises the supplied Arabic consolidated compilation, the official text of Law No. 30 of 2023 for the wording of Article 4, and the official text of Law No. 151 of 2026 with its corrigendum. Constitutional notes are editorial annotations rather than wording added to the statute. The reference to an independent agent in Article 4, Second, item (d), is translated literally from the Arabic and should be considered together with the remainder of Article 4; the English text does not silently reverse that wording.
For advice on how the legislation applies to your company’s circumstances, contact Consortio Law Firm.
