PE domestic law
Egypt amends PE definition
On 20 June 2023, Egypt published in the Official Gazette amendments to the Income Tax Law No 91 of 2005. In part, the amendments broaden the definition of Permanent Establishment (PE) and incorporate elements from BEPS Action 7. Specifically, they include the Agency PE provision, addressing splitting-up of contracts, and the independent-agent clause applicable in cases of an agent acting on behalf of a closely related person.
Additionally, Egypt has intro…