On 21 October 2018, Egyptian Ministry of Finance has issued new decree 547 providing the authority for new transfer pricing guidelines to be published. The new guidelines introduced three-tiered level of transfer pricing reports for transparency to include Master File, for the ultimate holding company of the group, Local File for each subsidiary in the group and CbCR to be submitted in the specific deadline.
Master File: The documentation requirement depends on the country of the ultimate parent deadline submission. The master file should be made available to the ETA based on the parent entity’s tax return filling date in its home jurisdiction.
Local File: A taxpayer who enters into cross-border transactions with related parties is expected to prepare local transfer pricing documentation and submit it to ETA within two months following the filling of the annual corporate tax return. The first report should be prepared for the group’s fiscal year ending 31 December 2018.
CbC reporting: An Egyptian parent company of a multinational group with consolidated group revenue of at least EGP 3 billion (€148m) will have to file a country-by-country (CbC) report (CbCR) in Egypt by 31 December 2019. Egyptian subsidiaries of foreign-parented groups with consolidated group revenue of at least of €750 million will be also required to file a report with the jurisdiction in which the ultimate parent entity is resident. The first CbC report should be prepared for the group’s fiscal year ending 31 December 2018.
