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Egypt Introduces New Amendments to the Income Tax Law No. 91 of 2005

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Egypt Law No. 30 of 2023 introduced new amendments to the Income Tax Law No. 91 of 2005 impacting Corporate Income Tax, Capital Gains Tax, definition of Permanent Establishment, Interest Deductibility, and Personal Income Tax.

Some of the main changes brought by Law No. 30 of 2023 are listed as follows:

Corporate Income Tax

  • Requiring submissions of electronic Invoices or receipts for costs and expenses to receive tax deductibility. The compliance deadline for e- bills is from July 2023 and for e-receipts from January 2025 subject to Minister’s extension of the deadline for not more than one year.
  • Introducing a flat tax rate on dividends received by a natural person (5%) or juridical person (15%).
  • Introducing the definition of Closely Related Enterprises.
  • Amendments to the definition of Permanent Establishment, dependent agent, and independent agent scope.

Interest Deductibility

  • Gradual reduction of the 4:1 debt to equity ratio of the thin capitalization to 2:1 over a five-year period as follows:

4:1 for the taxable year 2023.

3:1 for the taxable year 2023-2027.

2:1 for the taxable year 2028.

Capital Gains Tax

  • Deferring the unpaid capital gains tax realized by juridical or natural persons from selling their shares in the Egyptian Stock Exchange before 15 of June 2023.
  • Extending the deadline for 60 days from the date of executing the transaction for non-residents to apply for CGT.

Personal Income Tax

  • The first income tax bracket subject to (0%) tax increased to 21,000 L.E from 15,000 L.E.
  • Increasing the personal exemption amount to 15,000 L.E from 9,000 L.E.
  • Implementing a new tax bracket of 27.5% on Individuals Annual Income that exceeds 1.2 million L.E

To view the full text of the amending Law No. 30 of 2023 and the amended Law No. 91 of 2005.

Ashrakat Sayed
By Ashrakat Sayed

Ashrakat joined Thomson Reuters in 2022 as a Content Specialist. She is a graduate with Bachelor's Degree from York University, and a Paralegal Diploma from Seneca College. Ashrakat is also a Licensed Paralegal by the Law Society of Ontario, Canada. She is a native Arabic speaker and fluent in English. 

Ashrakat is currently a Legal Editor for Thomson Reuters MENA. She is based in Dubai and is responsible for maintaining and providing the latest legal content updates in the MENA region. 

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