Minister of Finance Decision No. 534 of 2025 raises the annual related-party transaction threshold, easing reporting requirements for smaller and mid-sized businesses.
Egypt’s Ministry of Finance (MoF) has issued Minister of Finance Decision No. 534 of 2025 of 17 December 2025, revising the rules for transfer pricing (TP) documentation. Under the decision, the annual related-party transaction threshold for TP reporting has been raised to EGP 30 million from EGP 15 million.
Companies with transactions below this level are no longer required to submit a master file, local file, or country-by-country (CbC) report.
The change forms part of Finance Minister Ahmed Kouchouk’s first tax facilitation package and aims to ease compliance for smaller and mid-sized businesses while maintaining reporting obligations for larger taxpayers.
The decision is effective immediately, including the current tax period.
Earlier, Egypt published the Ministerial Decree No. 52 of 2024 in the Official Gazette on 15 February 2024, providing updated transfer pricing documentation requirements for Egyptian taxpayers.
