BEPS 2.0 Explained – What Multinationals Should Prepare for in 2025

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 […]

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Case Study: Successful WHT Refund for a Multinational Operating in Egypt

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

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Intercompany Loans

How BEPS Action 6 (Treaty Abuse) Affects Access to Treaty Benefits

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,

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Understanding the Impact of DTT Articles 12 and 15 on WHT Obligations

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

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WHT Treatment of Software, Royalties, and Technical Services under Egypt’s Tax Law

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

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How to Interpret WHT Clauses in Service and Licensing Agreements

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

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Common Reasons for WHT Refund Rejections and How to Avoid Them

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

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WHT Refund Documentation Checklist

Documentation Checklist for Successful Withholding Tax Refund Claims in Egypt

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

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Step-by-Step Guide to Applying for WHT Refunds in Egypt

Step-by-Step Guide to Applying for WHT Refunds in Egypt

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

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Transfer Pricing Adjustments in Egypt

Transfer Pricing Adjustment in Egypt – A Practical Guide for Multinationals

Introduction Transfer pricing (TP) adjustments have become increasingly important for multinationals operating in Egypt, especially as the Egyptian Tax Authority (ETA) intensifies its scrutiny of related-party transactions. Differences between budgeted and actual margins, currency volatility, market fluctuations, and changes in supply chain structures often lead to profitability deviations from the arm’s-length range. A transfer pricing

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Key Lessons from OECD 2022 TP Guidelines Updates for Egyptian Multinationals

Introduction In September 2022, the Organisation for Economic Co‑operation and Development (OECD) released significant updates to its Transfer Pricing Guidelines including new rules on financial transactions and intangible assets, a strengthened emphasis on economic substance, and refined guidance on hard-to-value intangibles (HTVIs). For multinationals based in Egypt or with operations in Egypt these changes carry

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Transfer Pricing in the Service Industry:

TP in the Service Industry: Handling Shared Resources Across Borders

Introduction As multinational enterprises (MNEs) expand, shared services become essential for achieving efficiency, scalability, and operational integration. Functions like HR, IT, finance, procurement, strategic planning, and marketing are increasingly centralized to reduce cost and ensure consistency across regions. But with this centralization comes a major transfer pricing challenge: How should shared resources across borders be

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