On 15 February 2024, Egypt published the Ministerial Decree No. 52 of 2024 in the Official Gazette, providing updated transfer pricing documentation requirements for Egyptian taxpayers. This decree came into effect on 22 February 2024.
In this Decree, the materiality threshold for the Master File and Local File has been raised from EGP 8 million to EGP 15 million. The revised materiality threshold will apply to the total value of intra-group transactions in the corresponding fiscal year. This materiality threshold increase relates to a change in Article 12 of Unified Procedures Law No. 206 of 2020.
The updated TP documentation compliance requirements are expected to create a more conducive environment for businesses involved in cross-border or domestic intercompany transactions. However, Egyptian taxpayers must ensure their transactions adhere to arm’s length standards and principles. In addition, existing transfer pricing regulations and compliance obligations will remain in effect.