Egypt Tax Guide
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Egypt Tax Guide
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Egypt
Tax Guide
2012
foreword
A country’s tax regime is always a key factor for any business considering moving
into new markets. What is the corporate tax rate? Are there any incentives for
overseas businesses? Are there double tax treaties in place? How will foreign source
income be taxed?
Since 1994, the PKF network of independent member firms, administered by PKF
International Limited, has produced the PKF Worldwide Tax Guide (WWTG) to provide
international businesses with the answers to these key tax questions. This handy
reference guide provides clients and professional practitioners with comprehensive
tax and business information for 100 countries throughout the world.
As you will appreciate, the production of the WWTG is a huge team effort and I
would like to thank all tax experts within PFK member firms who gave up their time
to contribute the vital information on their country’s taxes that forms the heart of this
publication. I would also like thank Richard Jones, PKF (UK) LLP, Kevin Reilly, PKF
Witt Mares, and Kaarji Vaughan, PKF Melbourne for co-ordinating and checking the
entries from countries within their regions.
The WWTG continues to expand each year reflecting both the growth of the PKF
network and the strength of the tax capability offered by member firms throughout
the world.
I hope that the combination of the WWTG and assistance from your local PKF
member firm will provide you with the advice you need to make the right decisions
for your international business.
Jon Hills
PKF (UK) LLP
Chairman, PKF International Tax Committee
jon.hills@uk.pkf.com
I PKF Worldwide Tax Guide 2012
important disclaimer
This publication should not be regarded as offering a complete explanation of the
taxation matters that are contained within this publication.
This publication has been sold or distributed on the express terms and understanding
that the publishers and the authors are not responsible for the results of any actions
which are undertaken on the basis of the information which is contained within this
publication, nor for any error in, or omission from, this publication.
The publishers and the authors expressly disclaim all and any liability and
responsibility to any person, entity or corporation who acts or fails to act as a
consequence of any reliance upon the whole or any part of the contents of this
publication.
Accordingly no person, entity or corporation should act or rely upon any matter or
information as contained or implied within this publication without first obtaining
advice from an appropriately qualified professional person or firm of advisors, and
ensuring that such advice specifically relates to their particular circumstances.
PKF International is a network of legally independent member firms administered by
PKF International Limited (PKFI). Neither PKFI nor the member firms of the network
generally accept any responsibility or liability for the actions or inactions on the part
of any individual member firm or firms.
PKF Worldwide Tax Guide 2012 II
preface
The PKF Worldwide Tax Guide 2012 (WWTG) is an annual publication that provides
an overview of the taxation and business regulation regimes of 100 of the world’s
most significant trading countries. In compiling this publication, member firms of the
PKF network have based their summaries on information current as of 30 September
2011, while also noting imminent changes where necessary.
On a country-by-country basis, each summary addresses the major taxes applicable
to business; how taxable income is determined; sundry other related taxation
and business issues; and the country’s personal tax regime. The final section of
each country summary sets out the Double Tax Treaty and Non-Treaty rates of tax
withholding relating to the payment of dividends, interest, royalties and other related
payments.
While the WWTG should not to be regarded as offering a complete explanation of
the taxation issues in each country, we hope readers will use the publication as their
first point of reference and then use the services of their local PKF member firm to
provide specific information and advice.
In addition to the printed version of the WWTG, individual country taxation guides are
available in PDF format which can be downloaded from the PKF website at www.pkf.com
PKF INTERNATIONAL LIMITED
APRIL 2012
©PKF INTERNATIONAL LIMITED
ALL RIGHTS RESERVED
USE APPROVED WITH ATTRIBUTION
III PKF Worldwide Tax Guide 2012
about pKf international limited
PKF International Limited (PKFI) administers the PKF network of legally independent
member firms. There are around 300 member firms and correspondents in 440
locations in around 125 countries providing accounting and business advisory services.
PKFI member firms employ around 2,200 partners and more than 21,400 staff.
PKFI is the 10th largest global accountancy network and its member firms have $2.6
billion aggregate fee income (year end June 2011). The network is a member of the
Forum of Firms, an organisation dedicated to consistent and high quality standards of
financial reporting and auditing practices worldwide.
Services provided by member firms include:
Assurance & Advisory
Corporate Finance
Financial Planning
Forensic Accounting
Hotel Consultancy
Insolvency – Corporate & Personal
IT Consultancy
Management Consultancy
Taxation
PKF member firms are organised into five geographical regions covering Africa; Latin
America; Asia Pacific; Europe, the Middle East & India (EMEI); and North America &
the Caribbean. Each region elects representatives to the board of PKF International
Limited which administers the network. While the member firms remain separate
and independent, international tax, corporate finance, professional standards, audit,
hotel consultancy, insolvency and business development committees work together to
improve quality standards, develop initiatives and share knowledge and best practice
cross the network.
Please visit www.pkf.com for more information.
PKF Worldwide Tax Guide 2012 IV
structure of country descriptions
a. taXes payable
FEDERAL TAXES AND LEVIES
COMPANY TAX
CAPITAL GAINS TAX
BRANCH PROFITS TAX
SALES TAX/VALUE ADDED TAX
FRINGE BENEFITS TAX
LOCAL TAXES
OTHER TAXES
b. determination of taXable income
CAPITAL ALLOWANCES
DEPRECIATION
STOCK/INVENTORY
CAPITAL GAINS AND LOSSES
DIVIDENDS
INTEREST DEDUCTIONS
LOSSES
FOREIGN SOURCED INCOME
INCENTIVES
c. foreiGn taX relief
d. corporate Groups
e. related party transactions
f. witHHoldinG taX
G. eXcHanGe control
H. personal taX
i. treaty and non-treaty witHHoldinG taX rates
V PKF Worldwide Tax Guide 2012
international time Zones
AT 12 NOON, GREENwICH MEAN TIME, THE sTANDARD TIME
ELsEwHERE Is:
A Guernsey . . . . . . . . . . . . . . . . 12 noon
Algeria . . . . . . . . . . . . . . . . . . . .1 pm Guyana . . . . . . . . . . . . . . . . . . . . 7 am
Angola . . . . . . . . . . . . . . . . . . . .1 pm
Argentina . . . . . . . . . . . . . . . . . . 9 am H
Australia - Hong Kong . . . . . . . . . . . . . . . . .8 pm
Melbourne . . . . . . . . . . . . .10 pm Hungary . . . . . . . . . . . . . . . . . . .1 pm
Sydney . . . . . . . . . . . . . . .10 pm
Adelaide . . . . . . . . . . . . 9.30 pm I
Perth . . . . . . . . . . . . . . . . . .8 pm India . . . . . . . . . . . . . . . . . . . 5.30 pm
Austria . . . . . . . . . . . . . . . . . . . .1 pm Indonesia. . . . . . . . . . . . . . . . . . .7 pm
Ireland. . . . . . . . . . . . . . . . . . 12 noon
B Isle of Man . . . . . . . . . . . . . . 12 noon
Bahamas . . . . . . . . . . . . . . . . . . . 7 am Israel . . . . . . . . . . . . . . . . . . . . . .2 pm
Bahrain . . . . . . . . . . . . . . . . . . . .3 pm Italy . . . . . . . . . . . . . . . . . . . . . .1 pm
Belgium. . . . . . . . . . . . . . . . . . . .1 pm
Belize . . . . . . . . . . . . . . . . . . . . . 6 am J
Bermuda . . . . . . . . . . . . . . . . . . . 8 am Jamaica . . . . . . . . . . . . . . . . . . . 7 am
Brazil. . . . . . . . . . . . . . . . . . . . . . 7 am Japan . . . . . . . . . . . . . . . . . . . . .9 pm
British Virgin Islands . . . . . . . . . . . 8 am Jersey . . . . . . . . . . . . . . . . . . 12 noon
Jordan . . . . . . . . . . . . . . . . . . . .2 pm
C
Canada - K
Toronto . . . . . . . . . . . . . . . . 7 am Kazakhstan . . . . . . . . . . . . . . . . .5 pm
Kenya . . . . . . . . . . . . . . . . . . . . .3 pm
Winnipeg . . . . . . . . . . . . . . . 6 am
Korea . . . . . . . . . . . . . . . . . . . . .9 pm
Calgary . . . . . . . . . . . . . . . . 5 am
Kuwait . . . . . . . . . . . . . . . . . . . . .3 pm
Vancouver . . . . . . . . . . . . . . 4 am
Cayman Islands . . . . . . . . . . . . . . 7 am
L
Chile . . . . . . . . . . . . . . . . . . . . . . 8 am
Latvia . . . . . . . . . . . . . . . . . . . . .2 pm
China - Beijing . . . . . . . . . . . . . .10 pm
Lebanon . . . . . . . . . . . . . . . . . . .2 pm
Colombia . . . . . . . . . . . . . . . . . . . 7 am
Liberia . . . . . . . . . . . . . . . . . . 12 noon
Croatia . . . . . . . . . . . . . . . . . . . .1 pm
Luxembourg . . . . . . . . . . . . . . . .1 pm
Cyprus . . . . . . . . . . . . . . . . . . . .2 pm
Czech Republic . . . . . . . . . . . . . .1 pm
M
Malaysia . . . . . . . . . . . . . . . . . . .8 pm
D Malta . . . . . . . . . . . . . . . . . . . . .1 pm
Denmark . . . . . . . . . . . . . . . . . . .1 pm Mauritius . . . . . . . . . . . . . . . . . . .4 pm
Dominican Republic . . . . . . . . . . . 7 am Mexico . . . . . . . . . . . . . . . . . . . . 6 am
Morocco . . . . . . . . . . . . . . . . 12 noon
E
Ecuador. . . . . . . . . . . . . . . . . . . . 7 am N
Egypt . . . . . . . . . . . . . . . . . . . . .2 pm Namibia. . . . . . . . . . . . . . . . . . . .2 pm
El Salvador . . . . . . . . . . . . . . . . . 6 am Netherlands (The). . . . . . . . . . . . .1 pm
Estonia . . . . . . . . . . . . . . . . . . . .2 pm New Zealand . . . . . . . . . . .12 midnight
Nigeria . . . . . . . . . . . . . . . . . . . .1 pm
F Norway . . . . . . . . . . . . . . . . . . . .1 pm
Fiji . . . . . . . . . . . . . . . . .12 midnight
Finland . . . . . . . . . . . . . . . . . . . .2 pm O
France. . . . . . . . . . . . . . . . . . . . .1 pm Oman . . . . . . . . . . . . . . . . . . . . .4 pm
G P
Gambia (The) . . . . . . . . . . . . . 12 noon Panama. . . . . . . . . . . . . . . . . . . . 7 am
Georgia . . . . . . . . . . . . . . . . . . . .3 pm Papua New Guinea. . . . . . . . . . .10 pm
Germany . . . . . . . . . . . . . . . . . . .1 pm Peru . . . . . . . . . . . . . . . . . . . . . . 7 am
Ghana . . . . . . . . . . . . . . . . . . 12 noon Philippines . . . . . . . . . . . . . . . . . .8 pm
Greece . . . . . . . . . . . . . . . . . . . .2 pm Poland. . . . . . . . . . . . . . . . . . . . .1 pm
Grenada . . . . . . . . . . . . . . . . . . . 8 am Portugal . . . . . . . . . . . . . . . . . . .1 pm
Guatemala . . . . . . . . . . . . . . . . . . 6 am Puerto Rico . . . . . . . . . . . . . . . . . 8 am
PKF Worldwide Tax Guide 2012 VI
Q
Qatar. . . . . . . . . . . . . . . . . . . . . . 8 am
R
Romania . . . . . . . . . . . . . . . . . . .2 pm
Russia -
Moscow . . . . . . . . . . . . . . .3 pm
St Petersburg. . . . . . . . . . . .3 pm
s
Sierra Leone . . . . . . . . . . . . . 12 noon
Singapore . . . . . . . . . . . . . . . . . .7 pm
Slovak Republic . . . . . . . . . . . . . .1 pm
Slovenia . . . . . . . . . . . . . . . . . . .1 pm
South Africa . . . . . . . . . . . . . . . . .2 pm
Spain . . . . . . . . . . . . . . . . . . . . .1 pm
Sweden . . . . . . . . . . . . . . . . . . . .1 pm
Switzerland . . . . . . . . . . . . . . . . .1 pm
T
Taiwan . . . . . . . . . . . . . . . . . . . .8 pm
Thailand . . . . . . . . . . . . . . . . . . .8 pm
Tunisia . . . . . . . . . . . . . . . . . 12 noon
Turkey . . . . . . . . . . . . . . . . . . . . .2 pm
Turks and Caicos Islands . . . . . . . 7 am
U
Uganda . . . . . . . . . . . . . . . . . . . .3 pm
Ukraine . . . . . . . . . . . . . . . . . . . .2 pm
United Arab Emirates . . . . . . . . . .4 pm
United Kingdom . . . . . . .(GMT) 12 noon
United States of America -
New York City. . . . . . . . . . . . 7 am
Washington, D.C. . . . . . . . . . 7 am
Chicago . . . . . . . . . . . . . . . . 6 am
Houston. . . . . . . . . . . . . . . . 6 am
Denver . . . . . . . . . . . . . . . . 5 am
Los Angeles . . . . . . . . . . . . . 4 am
San Francisco . . . . . . . . . . . 4 am
Uruguay . . . . . . . . . . . . . . . . . . . 9 am
V
Venezuela . . . . . . . . . . . . . . . . . . 8 am
Vietnam. . . . . . . . . . . . . . . . . . . .7 pm
VII PKF Worldwide Tax Guide 2012
Egypt
eGypt
Currency: EGP Dial Code To: 20 Dial Code Out: 00
Member Firm:
City: Name: Contact Information:
Cairo Hany Rashed 202 287 5340
rashed@ie-eg.com
a. taXes payable
FEDERAL TAxEs AND LEVIEs
CORPORATE INCOME AND GAINs TAx
Egyptian corporations are subject to corporate profits tax on their profits derived from
Egypt, as well as on profits derived from abroad, unless the foreign activities are
performed through a permanent establishment located abroad. Foreign companies
resident in Egypt are subject to tax only on their profits derived from Egypt. Oil
prospecting and production companies are subject to tax on their profits at a rate of
40.55%. The Suez Canal Company, Egyptian General Petroleum Company (EGPC)
and Central Bank of Egypt are subject to tax on their profits at a rate of 40%.
ADMINIsTRATION
Companies must file their annual tax returns, together with all supporting schedules and
the original financial statements, before 1 May each year or four months from the financial
year end. The tax return should be signed by the taxpayer. Taxpayers can file a request
to extend the due date of filing the tax return provided they pay an estimated amount of
tax. The request must be filed at least 15 days before the due date and the estimated tax
due must also be paid before the due date. The extended period can be up to 60 days. An
amended tax return can be filed within 30 days from the due date. Any tax due must be
paid when the tax return is filed. A late penalty is applied at the rate of 2% plus the credit
and discount rate issued by the Central Bank of Egypt as of January each year. The law
has set up appeals committees at two levels – the Internal Committee and the Appeal
Committee. The Appeal Committee’s decision is final and binding on the taxpayer and the
tax department unless a case is appealed by either to the court within 30 days of receiving
the decision, which is usually in the form of an assessment.
DIVIDENDs
Dividends distributed by an Egyptian company are not subject to withholding tax because
they are paid out of corporate profits that are taxed under the normal rules. Dividends
received by residents from foreign sources are not taxed in Egypt. Dividends are exempt
from tax. Interest on bonds listed on the Egyptian stock exchange is exempt from tax if
certain conditions are satisfied. Certain exemptions may be provided in some cases.
CORPORATE TAx RATEs
Nature of tax Rate
Corporate income tax – up to net profit 10,000,000 20%
Corporate income tax – net profit over 10,000,000 25%
Capital gains tax 20%
Branch tax 20%
Withholding tax:
Dividends 0%
Interest 20% (1)
Royalties from patents, know-how, etc. 20% (1)
Certain services provided from non-resident entities 20% (1)
Branch remittance tax 0%
Net operating losses (years)
Carry back 3 years
Losses incurred in long-term projects can be carried back within
the same project with no limits.
Carry forward 5 years
1. Final tax imposed on gross payments. The rate may be reduced under a tax treaty.
PKF Worldwide Tax Guide 2012 1
Egypt
OTHER TAxEs
The table below summarises other significant taxes.
Nature of tax Rate
General sales tax 0% to 30%
Customs duties:
– general, ad valorem Various
– on value of machinery needed for investments by companies 5%
Stamp duties on bills, promissory notes and letters of guarantee
as well as most types of documents, contracts, checks and Various
receipts (shares and bonds listed on the Egyptian Stock Exchange
are exempt)
The amounts paid become credits available for income tax purposes at the end of
the period.
sOCIAL INsURANCE
On monthly base salary, up to LE 875, paid by:
– Employer 26%
– Employee 14%
On amount in excess of LE 875 of the base salary, with a
maximum excess amount of LE 625 a month, paid by:
– Employer 24%
– Employee 11%
b. determination of taXable income
Corporate income tax is based on taxable profits computed in accordance with
generally accepted accounting and commercial principles, modified for tax purposes
by certain statutory provisions primarily concerning depreciation, provisions, inventory
valuation, inter-company transactions and expenses. Start-up and formation expenses
may be capitalised and amortised in the first year.
The deductibility of a branch’s share of head office overhead expenses is limited to
approximately 3% to 5% (according to practice) of turnover. Head office expenses other
than overhead and general administration expenses are subject to negotiation with the
tax authorities. They are fully deductible if they are directly incurred by the branch and
are necessary for the performance of the branch’s activity in Egypt. Such expenses
must be supported by original documents and approved by the head office auditors.
DEBIT INTEREsT
Debit interest of loans/overdraft used in the company’s activity is a deductible item
after offsetting the interest income. Interest expense paid to individuals who are not
subject to tax or exempted from tax is not deductible. Interest expense is limited to
the interest rate which will not exceed twice the discount rate determined by the
central bank of Egypt.
DEBT-TO-EQUITy RULEs
The tax law has determined the maximum debt to equity ratio to be 4:1. In the event
the debt exceeds such ratio, the excess interest is not accepted by the Tax Authority
to be a deductible expense. The law, however, has set a transition period (five years)
to allow companies that do not comply with the thin capitalisation ratio set by the law
the opportunity to change their position to comply with this ratio. The following ratios
are accepted by the tax authority during the transition period:
year Ratio
2005 8:1
2006 7:1
2007 6:1
2008 5:1
2009 4:1
2 PKF Worldwide Tax Guide 2012
Egypt
INVENTORIEs
Inventories are normally valued for tax purposes at the lower cost or market
value. Cost is defined as purchase price plus direct and indirect production costs.
Inventory reserves are not permissible deductions for tax purposes. For accounting
purposes, companies may elect to use any acceptable method of inventory
valuation such as first-in, first-out (FIFO) or average cost. The method should
be applied consistently and the reasons for such change should be stated if the
method is changed.
PROVIsIONs
Provisions are not considered as deductible costs except for the following:
• 80% of loan provisions made by banks (required by the Central Bank of Egypt)
• insurance companies provision determined by Law No 10 of 1981.
BAD DEBTs
Bad debts are deductible cost if the company provides a report from an external
auditor certifying the following:
• the company is maintaining regular accounting records
• the debt is related to the company’s activity
• the debt should appear in the company’s records
• the company should take the necessary action to collect the debt.
DEPRECIATION AND AMORTIsATION ALLOwANCEs
Depreciation is deductible for tax purposes and may be calculated using either the
straight-line or declining-balance method. Depreciation rates are as follows:
Type of asset Rate Method of Depreciation
Buildings 5% Straight-line
Intangible assets 10% Straight-line
Computers 50% Declining-balance
Heavy machinery and equipment 25% Declining-balance
Small machinery and equipment 25% Declining-balance
Vehicles 25% Declining-balance
Furniture 25% Declining-balance
Other tangible assets 25% Declining-balance
Accelerated depreciation is allowable only once at a rate of 30% on new machines
and equipment in the year they are placed into service. Normal depreciation is
calculated after considering the accelerated 30% depreciation on the net value of
new assets, provided that proper books of account are maintained.
Tax losses may be carried forward for five years. Losses incurred in long-term
projects can be also carried back within the same project.
REAL EsTATE TAx
Egypt introduced a new tax law No 196 of 2008 with effect from 23 June 2008 to be
applied with effect from 1 January 2009.
Tax Rate: 10 % of the annual rental value after excluding the following representing
an assumed maintenance expenses:
• 30% of the rental value for properties used for living accommodation
• 32% of the rental for properties used for other purposes.
c. foreiGn taX relief
Foreign tax paid by a resident entity outside Egypt can be deducted provided there is
supporting documentation. Losses generated outside Egypt cannot be offset against
the taxable amount in Egypt. Treaties concluded between Egypt and other countries
regulate the credit for taxes paid abroad on income subject to corporate income tax
in Egypt.
d. corporate Groups
Associated or related companies in a group are taxed separately for corporate
income tax purposes. Egyptian law does not contain a concept of group assessment
under which group losses may be offset against profits within a group of companies.
PKF Worldwide Tax Guide 2012 3
Egypt
e. related party transactions
The Egyptian tax law contains provisions for transfer pricing. The transfer pricing provisions
are based on the arm’s length principle. Under these provisions, the tax authorities may
adjust the income of an enterprise if its taxable income in Egypt is reduced as a result of
contractual provisions that differ from those that would be agreed to by unrelated parties.
However, it is now possible to enter into arrangements with the tax department to agree a
transfer pricing policy in advance (Advance Pricing Arrangement). This provides assurances
that transfer prices will not be challenged after the tax return is submitted, with the
consequent exposure to penalties and interest on late paid taxes.
f. witHHoldinG taX
No withholding tax is levied on dividends distributed by resident companies, regardless
of the residence status of the recipient. Interest derived by non-resident legal persons is
subject to a final withholding tax at the rate of 20% on the gross amount, unless a lower
treaty rate applies. Royalties derived by non-resident legal persons are subject to a final
withholding tax at the rate of 20% on the gross amount, unless a lower treaty rate applies.
G. eXcHanGe control
Egypt has a free market exchange system. Exchange rates are determined by supply
and demand without interference from the central bank or the Ministry of the Economy.
H. personal taX
Income tax is imposed on the worldwide income of Egyptian residents. Non-residents
are subject to tax on income earned or realised in Egypt.
An individual is deemed to be a resident of Egypt if:
• the individual is present in Egypt for more than 183 days in a fiscal year
• the individual’s principal place of residence is Egypt. Article 2 of the Executive
Regulations states that an individual is considered to have a permanent
residence in Egypt if:
(a) the taxpayer stays in Egypt for the majority of the year, either in his own
property, in a rented property or in any other place
(b) the taxpayer has a local commercial presence, professional office,
industrial site or any other place where he carries on his activities in Egypt
(c) the individual is an employee who performs his duties abroad and receives
a salary from an Egyptian public or private source.
Income tax is assessed each year on the aggregate of the net amounts from each
category of income realised during the preceding year. There are four recognised
categories of income, namely:
(1) employment income
(2) business income (which includes income from commercial and industrial
activities)
(3) non-commercial income
(4) income from real estate assets.
Graduated rates apply with effect from 1 July 2005 to the aggregate of the four
categories of income, as follows:
Income (EGP) Rate
Up to 5,000 0%
5,001 to 20,000 10%
20,001 to 40,000 15%
40,001 to 10,000,000 20%
Over 10,000,000 25%
Individuals are not subject to a tax on capital gains except in the case of the disposal of
real estate or building sites within the boundaries of Egyptian cities. Such gains are not
subject to income tax but are taxed at the rate of 2.5% on the value of the property.
i. treaty witHHoldinG taX rates
Dividends paid to non-residents are not subject to withholding tax under Egyptian
domestic law. Consequently, the following table sets forth maximum withholding rates
provided in Egypt’s tax treaties for interest and royalties only.
4 PKF Worldwide Tax Guide 2012
Egypt
Egypt has signed double tax treaties with Armenia, Bangladesh, Greece, Ireland,
Kazakhstan, Mongolia, Norway, Oman, Senegal, Seychelles, the Slovak Republic,
Spain, Sri Lanka, Tanzania, Thailand, Uganda and Vietnam but these treaties have not
yet been ratified.
Tax treaty negotiations are underway with Congo, Macedonia and North Korea.
Interest Royalties
(%) (%)
Non-Treaty Countries: 20 20
Treaty Countries:
Albania 10 10
Algeria 5 10
Austria 15 0
Bahrain – (1) – (1)
Belarus 10 15
Belgium 15 15/20
Bulgaria 12.5 12.5
Canada 15 15
China 10 8
Cyprus 15 10
Czech Republic 0 10
Denmark 15 20
Finland (1)
From Finland 0 20
From Egypt 20 20
France 20 15/20 (3)
Germany 15 15/20 (3)
Hungary 15 15
India 20 – (1)
Indonesia 15 15
Iraq:
From Iraq 10 15
From Egypt 20 15
Italy 20 15
Japan 20 15
Jordan 15 20
Korea (South) 10/15 15
Kuwait 10 10
Lebanon 10 5
Libya 20 20
Malaysia 15 15
Malta 10 12
Morocco 20 10
Netherlands 12 12
Norway:
From Norway 0 0
From Egypt 20 15
Pakistan 15 15
Palestine 15 15
Poland 12 12
Romania (4) 15 15
PKF Worldwide Tax Guide 2012 5
Egypt
Interest Royalties
(%) (%)
Russia 15 15
Singapore 15 15
South Africa 12 15
Sudan 20 10/3 (5)
Sweden 15 14
Switzerland 15 12.5
Syria 15 20
Tunisia 10 15
Turkey 10 10
Ukraine 12 12
United Arab Emirates 10 10
United Kingdom 15 15
United States 15 15
Yemen 10 10
Yugoslavia (6) 15 15
1 According to domestic law in each country.
2 A final draft of a new tax treaty with Finland was initialled on 17 September
1997 but the new treaty has not yet been ratified.
3 The higher rate applies to trademarks.
4 The treaty with Romania is being renegotiated.
5 Films, otherwise 10%.
6 The treaty with Yugoslavia applies to the republics that formerly comprised
Yugoslavia
6 PKF Worldwide Tax Guide 2012
$100 www.pkf.com
PKF Worldwide Tax Guide 2012 565
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