On 19 September 2023, the Egyptian Tax Authority issued Explanatory Instruction No. 78 introducing mandatory transfer pricing reporting obligations for related party transactions. Accordingly, the Tax Authority has set deadlines for submitting transfer pricing local files along with the corporate income tax (CIT) return, and these deadlines are as follows:

Due date for the submission of original CIT returns Due date for the submission of local file
15 April 15 June
20 April 20 June
30 April 30 June

In case of amended CIT, the following deadlines are applicable:

Due date for the submission of amended CIT returns Due date for the submission of local file
2 May 2 July
7 June 7 August
15 June 15 August

Moreover, the Tax Authority has also provided the following clarifications on transfer pricing reporting obligations:

  • capital gains are exempt from mandatory transfer pricing reporting;
  • transactions impacting balance sheets and intra-group expenses should be reported in table no. 508 of the annual CIT return;
  • shared projects require proportional reporting for related parties;
  • affiliate entities of a free zone parent or holding company need to submit the master file along with the local file.