Introduction As the OECD’s Pillar Two Global Minimum Tax (GMT) framework comes into effect, multinational enterprises (MNEs) around the world including those operating in Egypt and the wider MENA region are facing a major transformation in how they calculate, report, and manage their global tax obligations. Pillar Two introduces a 15% minimum effective tax rate […]
Top 5 Challenges in Implementing Pillar Two Compliance Read More »
Introduction The OECD’s global tax reform especially BEPS 2.0, with its two pillars on profit reallocation and the Global Minimum Tax (GMT) – is reshaping how multinational enterprises (MNEs) are taxed worldwide. For countries in the Middle East and North Africa (MENA), this reform is more than a technical tax update. It touches on investment
How Egypt and Other MENA Countries Are Responding to OECD’s Global Tax Reform Read More »
Introduction The Global Minimum Tax (GMT) under OECD BEPS 2.0 Pillar Two represents one of the most significant shifts in international taxation in decades.Designed to ensure that large multinational enterprises (MNEs) pay a minimum effective tax rate (ETR) of 15% regardless of where they operate, Pillar Two will reshape tax structures across the Middle East
Understanding the Global Minimum Tax (Pillar Two) and Its Impact on MENA Groups Read More »
Introduction BEPS 2.0 represents the most transformative global tax reform since the original OECD BEPS package launched a decade ago.As we approach 2025, multinational groups in Egypt, the Middle East, and around the world must begin preparing for the practical adoption of: Pillar One Amount A (Reallocation of taxing rights) Pillar Two Global Minimum Tax
BEPS 2.0 Explained – What Multinationals Should Prepare for in 2025 Read More »
Introduction Withholding Tax (WHT) refunds in Egypt are often seen as complex, time-consuming, and uncertain.Many multinational companies either give up or fail to submit complete, compliant documentation leading to rejections, delays, or reduced refund amounts.However, a well-structured approach can transform the process from a challenging obligation into a successful recovery of significant cash. This case
Case Study: Successful WHT Refund for a Multinational Operating in Egypt Read More »
Introduction Base Erosion and Profit Shifting (BEPS) Action 6 also known as the Treaty Abuse Action represents one of the most significant global tax reforms in the last decade.Its purpose is simple but far-reaching: Stop multinationals from accessing treaty benefits when they are not entitled to them. Before BEPS, many companies used treaty-shopping structures, conduit entities,
How BEPS Action 6 (Treaty Abuse) Affects Access to Treaty Benefits Read More »
Introduction Double Tax Treaties (DTTs) play a critical role in determining whether cross-border payments are subject to Withholding Tax (WHT). Among the most important treaty articles for multinational groups operating in Egypt and MENA are: Article 12 – Royalties Article 15 – Income from Employment These two articles define who has the taxation right, how
Understanding the Impact of DTT Articles 12 and 15 on WHT Obligations Read More »
Introduction Egypt’s Income Tax Law and Executive Regulations impose withholding tax (WHT) on a wide range of cross-border payments. However, one of the most complex and frequently misunderstood areas relates to the classification and taxation of: Software payments Royalty and licensing fees Technical and consultancy services Misclassifying these payments can lead to over-withholding, disputes with
WHT Treatment of Software, Royalties, and Technical Services under Egypt’s Tax Law Read More »
Introduction Withholding Tax (WHT) is one of the most financially sensitive components in service agreements, licensing contracts, software arrangements, and cross-border commercial relationships.A single clause often overlooked can determine: Who bears the tax cost Whether treaty benefits apply How much the recipient actually receives Whether the contract complies with Egyptian tax rules Misinterpreting WHT clauses
How to Interpret WHT Clauses in Service and Licensing Agreements Read More »
Introduction Withholding Tax (WHT) refunds in Egypt can offer significant financial relief for foreign companies and multinationals receiving cross-border payments.But despite eligibility under Double Tax Treaties (DTTs), many refund applications are rejected by the Egyptian Tax Authority (ETA) due to documentation gaps, misinterpretation of treaty rules, or inconsistencies in the refund file. Understanding why refund
Common Reasons for WHT Refund Rejections and How to Avoid Them Read More »
Introduction Withholding Tax (WHT) refunds in Egypt can save multinational companies significant amounts of money but only when the documentation is complete, consistent, and aligned with Egyptian tax laws and Double Tax Treaties (DTTs).The Egyptian Tax Authority (ETA) approves refunds only when the taxpayer provides strong proof of eligibility, actual payment, beneficial ownership, and treaty
Documentation Checklist for Successful Withholding Tax Refund Claims in Egypt Read More »
Introduction Withholding Tax (WHT) is one of the most common taxes applied in Egypt on payments made to foreign entities for services, royalties, interest, and other cross-border transactions. Many multinationals end up overpaying WHT due to incorrect rates, missing treaty benefits, or misclassification of services and the only way to correct this is by filing
Step-by-Step Guide to Applying for WHT Refunds in Egypt Read More »