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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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Description: Egypt Tax Guide