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…