Egypt: Law No. 30 establishing threshold for determining existence of permanent establishment for taxation purposes entered into force

On 16 June 2023, Law No. 30 of 2023 amending some provisions of the Income Tax Law No. 91 of 2005 and of the Law No. 182 of 2020 abolishing the exemption imposed on returns on treasury bills and bonds or capital gains resulting from dealing in these bills and bonds from income tax, entered into force. The law mandates electronic invoices from July 2023 and receipts from January 2025 for tax-deductible expenses. The “Service Permanent Establishment (PE)” applies to non-resident entities providing services in Egypt for over 90 days in a 12-month period. The “Agency PE” definition expands to include contract facilitation. Transfer pricing aligns with international standards, and specific mutual funds are exempt from corporate income tax. Capital gains incentives include waivers for share swaps and Initial Public Offerings (IPOs) on the Egyptian Stock Exchange. Non-residents must declare tax on unlisted financial instruments within 60 days. Payroll tax compliance requires electronic reporting from 2024. Thin-capitalisation ratios will phase down over five years.