Egypt Transfer Pricing Documentation Requirements
Egypt requires a Master File and Local File where a taxpayer's domestic or international intercompany transactions reach EGP 8 million in the year. Non-submission carries a penalty geared to the value of the related-party transactions, and the burden of proof shifts to a taxpayer that cannot show how its prices were set.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Intercompany transactions ≥ EGP 8m (domestic and/or international) | By the Master File deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | EN / AR | Yes (3% of the annual related-party transaction amount) |
Local File Required | Same EGP 8m threshold as the Master File | By the Local File deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | AR / EN | Yes (3% of the annual related-party transaction amount) |
CbC report Required | Group revenue ≥ EGP 3,000m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Egypt deadline
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Scope of the documentation obligation
A taxpayer whose domestic or international intercompany transactions reach EGP 8 million during the year must submit a Master File and a Local File; those below that level are not required to do so. Related-party transactions are disclosed on the corporate tax return in a dedicated table rather than through a separate transfer pricing return.
Distinctive features of the Egyptian regime
Two features distinguish the Egyptian regime. The first is the value-based penalty, set at 3 percent of the annual amount of the related-party transactions where the company does not submit the Master File or Local File, which scales the consequence to the size of the dealings rather than applying a fixed sum. The second is the burden-of-proof mechanism: the burden rests initially with the tax authority, but it shifts to the taxpayer where the taxpayer fails to provide documents showing how its transfer prices were established, so the practical effect of missing documentation is to move the evidential burden. There is no published safe harbour.
Benchmarking and comparables
Given the lack of local comparable data, the tax authority accepts Middle East and Africa comparables, and global comparables where sufficient effort is shown to demonstrate that local comparables are unavailable. Multi-year analysis over three years is preferred. A fresh benchmarking search is not required every year, but the financials of a prior study must be updated, with a fresh study generally conducted every three years. The limitation period is five years.
Frequently asked questions
How is the Egyptian documentation penalty calculated?
Where a company does not submit the Master File or Local File, the penalty is 3 percent of the annual amount of the related-party transactions, so it scales with the size of the dealings rather than being a fixed sum.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.