The Egyptian Tax Authority (ETA) has published the final update of the Egyptian Transfer Pricing Guidelines, which reflect the outcomes of the OECD BEPS project, including the three-tiered documentation requirements. The guidelines were developed based on the OECD's 2017 Transfer Pricing Guidelines, which should be referenced as needed for a more detailed discussion of the transfer pricing principles.
Some of the key aspects of the updated guidelines as compared to prior guidelines include:
With respect to documentation requirements, the guidelines include that in the case of preparing and maintaining transfer pricing documents in languages other than Arabic, the ETA may require the taxpayer, at its own expense, to submit an official translation of the required documents. With respect to CbC reporting, the guidelines note that further practical guidance will be issued on format, instructions, electronic filing, etc.
The guidelines also note that the ETA will issue separate guidelines to address the application of the arm's length principle to transactions involving intangible property, controlled services, and cost contribution arrangements. In addition, separate guidelines will be issued regarding the tax treatment of Permanent Establishments including the attribution of profits with the head office, as well as guidelines to address key transfer pricing issues for certain industries.
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