The treaty provides that, where a company is considered to be established in the two contracting states, the competent authorities determine their residence by mutual agreement. In the absence of an agreement, the company is not entitled to tax relief or tax exemptions under the contract. Other customs taxes apply to skilled goods and services, including a 5% tax on machinery. The amounts paid for these taxes can be converted into tax credits at the end of the period. A solidarity contribution of 0.25% of annual revenues to the financing of public health insurance is collected by public authorities, partnerships and companies are required to pay. The Double Taxation Convention came into force on August 23, 1980. Tax treaties and related documents between the United Kingdom and Egypt. . For dividends paid by Egyptian companies to resident partners, a 10% or 5% WHT is collected. For more information, see the dividends received in the “Results” section. For payments withheld on behalf of non-resident businesses, the tax is transferred to the IRS the day after the withholding tax.

Residents are taxed on their global income when their business, industrial or professional centre is located in Egypt. The contract provides that a stable establishment is considered constituted when a company engages in activities involving the use of essential equipment (including the installation of such equipment) carried out in a contracting state in connection with the exploitation, exploration or exploitation of natural resources in that state. Egypt has entered into TTDs with more than 50 countries that could change the tax treatment of transactions between Egyptian institutions and residents of a contracting country. The payment of dividends, interest, royalties and services by a national capital company to foreign or non-resident entities is subject to the WHT as follows. There are two different types of stamp duty levied on legal documents, deeds, bank transactions, business start-ups, insurance premiums and other transactions as follows: nominal stamp duty is levied on documents, regardless of their value. The tax rate for items such as contracts is 0.9 for each paper; proportional or percentage stamp duty is levied on the basis of the value of the transactions. This proportional stamp duty has been extended to balances and acquisitions representing at least 33% of the shares or 33% of the assets/liabilities of the resident companies. Transactions within the jurisdiction of the new Investment Act are exempt from stamp duty for 15 years. Finally, a proportional annual stamp duty of 0.4%, shared by the bank and the customer, is levied on a bank`s loans.

Interest on loans over three years made by private sector companies is exempt from WHT, while loans of less than three years are subject to 20% wht on interest. However, an applicable DTT between Egypt and abroad can lead to a reduction in this rate. Please note below for the ministerial decree on the treatment of interest and royalties. Rates can be reduced under an applicable tax treaty. However, the question of whether (i) the decree will be removed and that the reduced rate of the DTT should apply automatically or (ii) the decree is in place and the refund mechanism should apply. In practice, ETA continues to apply the refund mechanism and resident companies should continue to deduct the 20% of WHT in accordance with national law and the non-resident party should require reimbursement from ETA. Egypt has entered into tax agreements with the following countries: the agreement is concluded in Egypt from 1 January 1977 and in the United Kingdom: Note: `The Greater the Index, the More Transparent the Conditions of Transactions.