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GCC ↔ Africa · Worked example

A UAE investor sets up an operating company in Egypt

A UAE company sets up and funds an Egyptian operating company under Egypt's Investment Law to produce goods or provide services in Egypt, with an eye on incentives and export. It must deal with Egypt's incorporation, tax, incentive, foreign exchange and employment rules, and with UAE corporate tax on the holding company, using the Egypt-UAE tax treaty and investment protections.

Source-checked research98% of statements checked against a source26 checked against an official source13 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed

This journey assumes

  • The investor is a UAE-incorporated company (a mainland LLC or a free-zone company) that is UAE tax resident and will hold at least 10% of the Egyptian company, in practice usually all of it.
  • The Egyptian company will operate under Investment Law No. 72 of 2017 in the internal investment framework unless a free zone or the Suez Canal Economic Zone is chosen.
  • The Egyptian company will not carry on banking, insurance or other regulated financial activity, and the activity is open to foreign ownership.
  • A small number of managers will move from the UAE to Egypt; most staff will be Egyptian.
  • Rules are stated as at 19 October 2026. Egyptian foreign exchange practice changes often and must be checked with banks at the time of each transfer.

If any assumption is wrong for your business, the conclusions change. Ask WONE Global to re-run the analysis with your facts.

Both sides of the border, issue by issue

Each row is one part of the work. The left and right columns show what each country's rules require, so you can see where one side's decision constrains the other.

Part of the workUnited Arab EmiratesEgypt

The UAE holding vehicle and the Egyptian company

Egypt's Investment Law gives foreign investors the same treatment as Egyptians and channels incorporation through GAFI, which must decide a complete application within one business day. The real decisions are which investment framework to use and which UAE company will hold the shares.

United Arab Emirates
  • A single UAE company or person can own a mainland LLC, so a dedicated UAE holding company is straightforward to form; free zones set their own shareholder rules.1
  • The UAE holding company must identify and record its beneficial owners: natural persons holding 25% or more or otherwise controlling it. The Egyptian side will ask for the same chain at incorporation and at the bank.2
Egypt
  • Foreign investors receive the same treatment as Egyptian investors under the Investment Law, although sector laws can still restrict foreign participation.3
  • The project can sit in one of four frameworks: internal investment, investment zones, technological zones or free zones. Free zones are export-oriented with their own customs and tax regime.4
  • GAFI handles incorporation under the Investment Law and the 1981 companies law, electronically where available; it must decide a complete application within one business day, and the company exists once entered in the Commercial Register.56

Egyptian tax, UAE tax and the Egypt-UAE treaty

The Egyptian company pays 22.5% corporate tax and charges 14% VAT. The Egypt-UAE treaty, in force since 2021, can cut Egyptian withholding on dividends from 10% to 5% for a UAE company holding at least 10% for 365 days. In the UAE, the holding company pays 9% corporate tax above AED 375,000 unless dividends are exempt or it is a Qualifying Free Zone Person; the participation exemption for foreign dividends was not source-checked here.

United Arab Emirates
  • UAE corporate tax is 0% up to AED 375,000 of taxable income and 9% above; the holding company must register and file within nine months of year end even if its income is mainly dividends.78
  • A free-zone holding company can pay 0% on qualifying income only if it meets all Qualifying Free Zone Person conditions, including substance, audited IFRS accounts and the de minimis limit.910
  • Loans, guarantees, management fees or royalties between the UAE company and the Egyptian company are related-party transactions that need arm's length pricing and, where required, UAE transfer pricing documentation.11
More in the United Arab Emirates guide →
Egypt
  • The Egyptian company pays corporate income tax at 22.5% and files its return within four months of its financial year end.1213
  • VAT is 14%, with a 5% rate for certain production machinery and schedule tax on specified goods and services.14
  • Egypt withholds 10% on dividends from unlisted shares to non-residents and 20% on royalties, service fees and interest; the Egypt-UAE treaty reduces this to 5% on dividends (with a 10% holding for 365 days) and 10% on interest and royalties.15161718
  • Egyptian transfer pricing documentation applies to related-party dealings with the UAE parent, with master and local files above a transaction threshold.19
More in the Egypt guide →

Incentives, zones and land

Egypt offers investment-cost deductions, a cash incentive for industrial projects funded in foreign currency, a single Golden License for strategic projects, and a free-zone regime outside the ordinary tax laws. Each has deadlines and conditions that should be checked before the company is incorporated. Land and premises rules were not covered in this journey.

United Arab Emirates
  • Foreign-currency funding from the UAE parent matters for Egypt's cash incentive for industrial projects, which rises with the share of the project financed in foreign currency.20
  • Dividends from an Egyptian free zone project are outside Egyptian tax, but when they reach the UAE holding company they fall under UAE corporate tax at 9% above AED 375,000 unless an exemption applies, which was not confirmed here.217
Egypt
  • A special incentive deducts 50% (Sector A) or 30% (Sector B) of investment costs from taxable profits, capped at 80% of paid-up capital and seven years; the incorporation deadline was extended to 28 October 2026, so timing is critical.22
  • Strategic or national projects meeting two or more criteria can apply for a Golden License, a single approval to set up, operate and manage the project.23
  • Free zone projects and their dividends are outside Egypt's tax laws but pay fees of 1% to 2% of goods value or revenue and an annual GAFI service amount of up to EGP 100,000.21

Importing inputs and exporting from Egypt

Egyptian customs duty ranges from 0% to 60% of CIF value by product, which is decisive for a project that imports inputs. Free zone and Suez Canal Economic Zone projects have duty and VAT advantages for export. Exports to the UAE face the UAE's generally 5% duty unless a preference applies; Arab free trade arrangements between the two were not source-checked.

United Arab Emirates
  • Goods shipped from Egypt into the UAE are generally charged 5% customs duty on CIF value under the GCC customs framework unless a preference applies; whether Egyptian goods qualify for Arab free trade preferences was not confirmed here.24
  • Because the UAE is part of the GCC Customs Union, a UAE distribution point can serve other GCC markets once goods have cleared customs into the UAE; destination rules should still be checked.24
More in the United Arab Emirates guide →
Egypt
  • Imports into Egypt bear customs duty of between 0% and 60% of CIF value depending on the product category.25
  • Free zone projects import and export goods, tools and machinery without customs duty or VAT, other than passenger vehicles.26
  • Goods and services exported from the Suez Canal Economic Zone are zero-rated for VAT.27
More in the Egypt guide →

Funding, foreign exchange and getting profits out

The Investment Law allows investors to transfer profits abroad and treats investment transfers as freely transferable in convertible currency. In practice, access to foreign currency through Egyptian banks has varied and must be planned with the bank. UAE banks will apply full due diligence to the flows.

United Arab Emirates
  • UAE banks must carry out customer due diligence when the relationship starts and on larger occasional transactions and wire transfers, so expect questions on the Egyptian investment and the source of funds.28
  • Dividends from Egypt arrive net of Egyptian withholding at 5% or 10%; whether the UAE then taxes them in the holding company depends on the participation exemption or free-zone rules, which were not confirmed here.187
More in the United Arab Emirates guide →
Egypt
  • Investors under the Investment Law may transfer profits abroad, and investment transfers are to be freely transferable in a freely convertible currency.29
  • GAFI states that investors may collect profits and transfer returns abroad without restrictions; how quickly banks can supply foreign currency at the time should still be confirmed.30
  • Central Bank of Egypt rules on registering foreign capital, the exchange rate regime and bank priority for foreign currency were not source-checked.
More in the Egypt guide →

Managers from the UAE and Egyptian staff

An investment project may employ foreign staff up to 10% of its workforce, or 20% where qualified Egyptians are not available. Social insurance is expensive at 18.75% for the employer, though contributions are capped. Foreign investors receive residence for the life of the project, and foreign staff may transfer their pay abroad.

United Arab Emirates
  • Managers moving from the UAE need Egyptian residence and work authorisation; investors themselves are granted residence for the project's duration.31
  • Whether UAE or GCC pension contributions can continue for a UAE national seconded to Egypt was not source-checked; most expatriate managers in the UAE are not in a UAE pension scheme.
More in the United Arab Emirates guide →
Egypt
  • Foreign workers may make up to 10% of the workforce of an investment project, rising to 20% where qualified Egyptian workers are not available.32
  • Employers pay 18.75% and employees 11% social insurance on the insurable salary, which from 1 January 2026 is between EGP 2,700 and EGP 16,700 a month; managers listed in the commercial register are insured at 21% of the maximum.3334
  • Foreign workers employed by investment projects may transfer their financial dues abroad.35
More in the Egypt guide →

Investment protection and resolving disputes

The Investment Law protects against nationalisation and limits expropriation, and gives investors a GAFI grievance route and ministerial committees for disputes with the state. Both countries apply the New York Convention, and a 1997 Egypt-UAE bilateral investment treaty is listed, though its status was not confirmed.

United Arab Emirates
  • The UAE has applied the New York Convention since 19 November 2006, so an award made in Egypt can be enforced in the UAE through the onshore courts.36
  • A 1997 Egypt-UAE bilateral investment treaty is listed by UNCTAD; its status and protections should be confirmed before structuring the holding through the UAE for treaty protection.37
Egypt
  • Investment projects may not be nationalised, and assets may be expropriated only for public utility with just compensation paid in advance.38
  • Complaints about decisions under the Investment Law go to a GAFI Grievance Committee within 15 business days, which decides within 30 days after hearings close; the investor can still go to court.39
  • Egypt has applied the New York Convention since 1959 without reservation.40

Structures to consider

01

UAE mainland holding company owning an Egyptian company in the internal investment framework121871119

Fits when The Egyptian company will sell mainly in Egypt, and the group wants a simple UAE holding company taxed under the standard regime.

Watch for Egyptian 22.5% tax; 5% treaty withholding on dividends only with a 10% holding for 365 days; UAE 9% on holding income unless an exemption applies (not confirmed here); transfer pricing on both sides.

02

UAE free-zone holding company with the Egyptian company in the internal framework91018

Fits when The group already has, or will build, real substance in a UAE free zone and wants the 0% Qualifying Free Zone Person rate on qualifying income.

Watch for All Qualifying Free Zone Person conditions must be met, including audited IFRS accounts, substance and the de minimis limit; whether dividends from Egypt count as qualifying income was not confirmed here.

03

Egyptian free zone or Suez Canal Economic Zone company for export production21262724

Fits when Most output will be exported, including to the UAE and other GCC markets, and inputs are largely imported.

Watch for Free zone projects pay 1% to 2% fees and a GAFI service amount instead of tax; sales into the Egyptian market are treated as imports; UAE customs duty generally 5% on arrival unless a preference applies.

These are the structures businesses commonly weigh, not a recommendation. The right one depends on the facts listed under "What we need from you".

What has to happen first

  1. United Arab EmiratesChoose the UAE holding company (mainland or free zone) and confirm its beneficial ownership records and tax registration.
  2. Both sidesDecide the Egyptian framework (internal, investment zone, technological zone, free zone or Suez Canal Economic Zone) and check sector restrictions on foreign participation.After step 1
  3. EgyptCheck eligibility and deadlines for Egyptian incentives, especially the investment-cost deduction with its 28 October 2026 incorporation deadline and the Golden License.After step 2
  4. EgyptIncorporate the Egyptian company through GAFI and register it in the Commercial Register.After step 2, 3
  5. Both sidesOpen Egyptian and UAE bank accounts, inject capital in foreign currency through the Egyptian bank and keep the transfer records.After step 4
  6. EgyptRegister the Egyptian company for corporate tax and VAT.After step 4
  7. EgyptSecure land or premises and any sector licences.After step 4
  8. Both sidesAgree intercompany agreements (funding, services, licences) and a transfer pricing policy that satisfies both Egyptian and UAE rules, and document treaty entitlement for 5% dividend withholding.After step 4, 5
  9. EgyptRecruit Egyptian staff, register for social insurance and obtain residence and work authorisation for managers from the UAE within the foreign staff limits.After step 4
  10. EgyptSet up customs registration and import procedures for inputs, and origin documentation for exports to the UAE.After step 4
  11. Both sidesStart operations; file the Egyptian corporate tax return within four months of year end and the UAE return within nine months.After step 6, 8, 9
  12. Both sidesDeclare and transfer dividends after holding at least 10% for 365 days to use the 5% treaty rate, and confirm the UAE tax treatment of the dividend.After step 11

What we need from you before anyone can advise

  • The exact activity of the Egyptian company and whether any sector law restricts foreign ownership or requires a licence.
  • Whether output will be sold in Egypt or exported, and to which markets.
  • Planned investment size, the share funded in foreign currency and the location (for Sector A or B incentives).
  • Which UAE company will hold the shares, where it is licensed and whether it has substance in a free zone.
  • How the Egyptian company will be funded (equity, shareholder loans) and any planned fees or royalties to the UAE.
  • Number of managers moving from the UAE and their nationalities.
  • Whether the group is part of a multinational with consolidated revenue of EUR 750 million or more.

What this guide does not yet confirm

These points need checking with a qualified local professional before you rely on them.

  • UAE participation exemption for dividends from an Egyptian subsidiary (ownership, holding period and subject-to-tax conditions) was not source-checked; the Decree-Law text and law-firm notes were blocked by rate limits.
  • Whether dividends from Egypt are qualifying income for a Qualifying Free Zone Person was not confirmed.
  • The Egypt-UAE treaty text could not yet be checked; entry into force and rates rely on secondary sources.
  • Egypt's Importers Register rules for foreign-owned companies (Law No. 121 of 1982 and later amendments) could not yet be checked; a trading or import-for-resale model must check them.
  • Egypt's Labour Law No. 14 of 2025 and foreign work permit procedures were not source-checked.
  • Central Bank of Egypt foreign exchange rules, capital registration and current exchange rate practice were not source-checked.
  • Greater Arab Free Trade Area preferences between Egypt and the UAE, and Egypt's AfCFTA status, were not confirmed (the GAFI trade agreements page was rate limited).
  • Status and entry into force of the 1997 Egypt-UAE bilateral investment treaty were not confirmed (UNCTAD page blocked).
  • Whether any social security agreement or GCC pension extension applies to UAE nationals working in Egypt was not checked.
  • Egyptian e-invoicing and e-receipt obligations were not source-checked.

Brief for your advisers

Questions to put to your advisers in each country. Copy them, or download them as a text file to send with your requirement.

  1. Egyptian corporate adviser: which investment framework fits our activity, what sector approvals apply, and can we incorporate before the 28 October 2026 incentive deadline?
  2. Egyptian tax adviser: what will we pay on profits, dividends, royalties and interest, and what paperwork do we need to claim the 5% treaty dividend rate?
  3. UAE tax adviser: are dividends from Egypt exempt under the UAE participation exemption, and does a free-zone holding company qualify for 0% on them?
  4. Both tax advisers: how should funding, management fees and any licences be priced and documented under Egyptian and UAE transfer pricing rules?
  5. Egyptian bank: how do we register our foreign capital, how long does access to foreign currency take for dividend transfers, and what documents will you need?
  6. GAFI or an investment adviser: do we qualify for the investment-cost deduction, the foreign-currency cash incentive or a Golden License?
  7. Egyptian employment adviser: how do the foreign staff limits, work permits and social insurance apply to our managers, and what does the current labour law require in contracts?
  8. Customs adviser: what duty applies to our imported inputs, and will our exports to the UAE qualify for any Arab free trade preference?
  9. Disputes adviser: is the 1997 Egypt-UAE investment treaty in force, and what dispute clause should our contracts and shareholder documents use?

Who can help, on each side

United Arab Emirates

Egypt

Sources and review status

Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.

  1. A limited liability company may have between 2 and 50 partners, and a single person may incorporate and own an LLC. Mainland LLCs under the Commercial Companies Law. Free zones set their own rules on shareholder numbers.

    Ras Al Khaimah Economic Zone (RAKEZ), hosting the federal text — Federal Decree-Law No. 32 of 2021 on Commercial Companies (English translation) · Article 71(1) and 71(2) · In force from 2 January 2022 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    English translation hosted by RAKEZ. The Arabic text prevails.

  2. A beneficial owner is a natural person who owns or ultimately controls a legal person directly or indirectly through 25% or more of the ownership, or who controls it by other means such as the right to appoint or remove most directors. Mainland and non-financial free zone legal persons. Excluded entities are set out in ae-establish-009. Where no person meets the test, the resolution provides fallback rules.

    UAE Legislation Platform — Cabinet Resolution No. (109) of 2023 Regulating the Real Beneficiary Procedures · Article 5(1) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    Cabinet Resolution No. 109 of 2023 replaced Cabinet Resolution No. 58 of 2020. JAFZA's guidance gives 15 December 2023 as its effective date; the resolution itself says it takes effect the day after Official Gazette publication.

  3. The Investment Law guarantees foreign investors the same treatment as national investors, and the Council of Ministers may grant preferential treatment to foreign investors on a reciprocity basis. Investors under Law No. 72 of 2017; sector-specific laws may still restrict foreign participation.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 3 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  4. Investment may be carried out under four frameworks: internal investment, investment zones, technological zones and free zones. Free zones are mainly export-oriented and have their own customs and tax regime.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Preamble Clause I; Articles 1, 28, 32 and 33 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  5. GAFI provides incorporation services for companies under the Investment Law and the 1981 companies law, and once electronic incorporation is activated only the electronic procedure applies. Companies Law No. 159 of 1981 and Investment Law companies.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 48 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  6. GAFI must decide on a complete incorporation application within one business day, and a company acquires legal personality on registration in the Commercial Register.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 51 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  7. Corporate tax is charged at 0% on taxable income up to AED 375,000 and at 9% on taxable income above AED 375,000. Federal; applies in all seven emirates and to mainland and free zone businesses unless the Qualifying Free Zone Person regime applies. Exempt persons are listed in ae-tax-017.

    Ministry of Finance — Cabinet Decision No. 116 of 2022 on the annual Taxable Income subject to Corporate Tax · Articles 2(1) and 3 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    Rates set by Article 3(1) of Federal Decree-Law No. 47 of 2022 with the threshold fixed by this Cabinet Decision.

  8. Every taxable person must register for corporate tax and file a corporate tax return no later than nine months after the end of the relevant tax period. Federal. The Minister may prescribe registration exceptions. Registration is required even where the business is already VAT-registered.

    Ministry of Finance — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses and its amendments · Articles 51 and 53 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    The FTA Corporate Tax page carries a news item that returns and payment for financial years ended 31 December 2025 were due by 30 September 2026.

  9. A Qualifying Free Zone Person can benefit from a 0% corporate tax rate on its qualifying income. Free-zone entities only, and only where all conditions are met. Non-qualifying income is taxed at 9%.

    UAE Ministry of Finance — Corporate Tax · Qualifying Free Zone Person section · In force from 1 June 2023 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  10. To be a Qualifying Free Zone Person an entity must maintain adequate substance in a free zone, derive qualifying income, not elect for standard taxation, comply with transfer pricing rules, prepare audited IFRS financial statements and keep non-qualifying revenue within the lower of 5% of total revenue or AED 5 million. Revenue of a domestic permanent establishment (for example a mainland branch), taxed separately at 9%, is excluded from the de minimis test.

    PwC Worldwide Tax Summaries — United Arab Emirates - Corporate - Tax credits and incentives (last reviewed 9 September 2026) · Free Zones section · In force from 1 June 2023 · Checked 18 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source; the Ministry of Finance page confirms the 0% regime but does not list the conditions, and the FTA Free Zone guide PDF could not yet be checked.

  11. Taxpayers must disclose related-party transactions with the tax return when required, keep a master file and local file where Ministerial conditions are met, and provide transfer pricing documentation within 30 days of an FTA request. Applies to transactions with related parties and connected persons, domestic or cross-border, whether the parties are on the mainland, in a free zone or abroad (FTA Corporate Tax FAQs).

    Ministry of Finance — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses and its amendments · Article 55 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    The revenue thresholds for master file and local file are set by Ministerial Decision (understood to be Ministerial Decision No. 97 of 2023) and were not confirmed here.

  12. The standard corporate income tax rate is 22.5 percent of net taxable profits. Oil exploration companies are taxed at 40.55 percent, and the Suez Canal Authority, Egyptian Petroleum Authority and Central Bank of Egypt at 40 percent.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Taxes on corporate income · Corporate income tax rate · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026.

  13. The corporate income tax return is due within four months after the end of the financial year, which is the taxpayer's own financial year.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Tax administration · Tax returns · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026.

  14. The standard VAT rate is 14 percent under VAT Law No. 67 of 2016, as amended by Law No. 157 of 2025, with a 5 percent rate for certain production machinery. Schedule (table) tax applies in addition to or instead of VAT on specified goods and services.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Other taxes · Value-added tax (VAT) · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026.

  15. Dividends paid to non-resident corporate shareholders are subject to withholding tax of 10 percent for unlisted shares and 5 percent for shares listed on the Egyptian Exchange. Domestic rates; treaties may reduce them.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Withholding taxes · Dividends · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026.

  16. Royalties and service fees paid to non-residents are subject to 20 percent withholding tax, and the non-treaty rate on interest is also 20 percent. Domestic rates; treaty relief may apply.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Withholding taxes · Royalties; services; treaty table non-treaty row · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026.

  17. A new Egypt-UAE income tax treaty, signed on 14 November 2019 to replace the 1994 treaty, entered into force on 19 April 2021 according to a UAE Ministry of Finance update. Comprehensive income tax treaty between Egypt and the UAE.

    Orbitax — New Tax Treaty between Egypt and the UAE (22 September 2021) · Introduction · In force from 19 April 2021 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source; the article is partly paywalled and the UAE Ministry of Finance treaty page could not yet be checked.

  18. Under the Egypt-UAE treaty, Egyptian withholding tax is limited to 5% on dividends, 10% on interest and 10% on royalties. The 5% dividend rate applies from January 2022 and only where treaty conditions are met, such as holding at least 10% of the shares for 365 days including the distribution date. Egypt's domestic rate on dividends from unlisted shares is 10%.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Withholding taxes (last reviewed 17 August 2026) · Treaty rate table - United Arab Emirates, note 6 · In force from 1 January 2022 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source; the treaty text could not yet be checked.

  19. Egyptian-parented groups with foreign subsidiaries must file a country-by-country report where annual consolidated group revenue is at least EGP 3 billion, and master file and local file obligations apply above a related-party transaction threshold. PwC gives the master and local file threshold as EGP 30 million but with conflicting references to the decision that set it.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Group taxation · Transfer pricing · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026. Confirm the current master and local file threshold with the Egyptian Tax Authority.

  20. Industrial projects financed at least 50 percent in foreign currency may receive a cash incentive of 35 to 55 percent of the income tax paid, depending on the foreign-currency share. Article 11 bis and Prime Minister Decree 77/2023; operations must start within six years.

    General Authority for Investment and Free Zones (GAFI) — Investment Incentives in Egypt (September 2026) · Article 11 bis · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  21. Free zone projects and their dividends are outside Egypt's tax laws, but pay fees of 1 to 2 percent of goods value or revenues depending on the zone and activity, plus an annual GAFI service amount capped at EGP 100,000. Public and private free zones.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 41 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  22. Projects may receive a special incentive of a deduction from taxable net profits of 50 percent of investment costs in Sector A areas or 30 percent in Sector B, capped at 80 percent of paid-up capital and seven years. Projects established after the Investment Law took effect; the incorporation deadline for this incentive was extended to 28 October 2026 by Prime Minister Decree 1/2024.

    General Authority for Investment and Free Zones (GAFI) — Investment Incentives in Egypt (September 2026) · Article 11, Law 72/2017 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  23. The Council of Ministers may grant a Golden License, a single comprehensive approval to set up, operate and manage a project, to strategic or national projects meeting two or more criteria. Article 20, Law 72/2017; criteria in Decree 56/2022.

    General Authority for Investment and Free Zones (GAFI) — Investment Incentives in Egypt (September 2026) · Golden License · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  24. UAE customs duty is generally charged at 5% of the CIF value of imports, and the UAE is part of the GCC Customs Union. Other rates apply to some goods such as alcohol and tobacco. Preferential CEPA rates can reduce this for qualifying Indian-origin goods.

    PwC Worldwide Tax Summaries — United Arab Emirates - Corporate - Other taxes (last reviewed 9 September 2026) · Customs duties · Checked 18 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source; Dubai Customs pages could not yet be checked.

  25. Customs duties on imported goods are charged at rates that vary by official product category, generally between 0 and 60 percent of CIF value.

    PwC Worldwide Tax Summaries — Egypt - Corporate - Other taxes · Customs duties · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026.

  26. Goods exported or imported by free zone projects are not subject to customs duties, VAT or other taxes and fees, and nor are their tools, equipment and machinery other than passenger vehicles.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 39 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  27. Exported goods and services from the Suez Canal Economic Zone (SCZone) are zero-rated for VAT.

    General Authority for Investment and Free Zones (GAFI) — Investment Incentives in Egypt (September 2026) · VAT incentives · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  28. Customer due diligence is required on starting a business relationship and, for financial institutions, on occasional transactions of AED 55,000 or more and occasional wire transfers of AED 3,500 or more; dealers in precious metals and stones must apply it to cash transactions of AED 55,000 or more. Federal. Virtual asset service providers: occasional transactions of AED 3,500 or more (Article 7(3)); commercial gaming operators: AED 11,000 or more.

    Ministry of Economy and Tourism — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 · Articles 3(3) and 7 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  29. Investors may transfer their profits abroad, and cash transfers for foreign investment are to be freely transferable in a freely convertible currency. Investors under Law No. 72 of 2017.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 6 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  30. GAFI states that investors may collect profits and transfer returns abroad without restrictions.

    General Authority for Investment and Free Zones (GAFI) — Investment Guarantees · Profit transfers · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  31. The state grants non-Egyptian investors residence for the duration of their projects, subject to the residency laws.

    General Authority for Investment and Free Zones (GAFI) — Investment Guarantees · Residence · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  32. An investment project may employ foreign workers up to 10 percent of its total workforce, rising to 20 percent where qualified Egyptian workers are not available. Projects under the Investment Law; green hydrogen projects may employ up to 30 percent in their first ten years.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 8 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails. Green hydrogen figure from GAFI's Investment Incentives guide (September 2026).

  33. Employee social insurance contributions are 11 percent and employer contributions 18.75 percent of the social insurance salary. Managers and board members listed in the commercial register are insured as employers at 21 percent of the maximum insurable salary.

    PwC Worldwide Tax Summaries — Egypt - Individual - Other taxes · Social security contributions · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026.

  34. From 1 January 2026 the maximum social insurance salary is EGP 16,700 and the minimum EGP 2,700. PwC does not state the period; these are understood to be monthly figures.

    PwC Worldwide Tax Summaries — Egypt - Individual - Other taxes · Social security contributions · In force from 1 January 2026 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source used because the Egyptian Tax Authority site could not be reached through the available tools; page last reviewed 17 August 2026. Period of the cap not stated by the source.

  35. Foreign workers employed by investment projects may transfer their financial dues abroad.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 8 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  36. The UAE acceded to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards on 21 August 2006, with entry into force on 19 November 2006, and the status table shows no declarations or reservations. Federal; applies to recognition and enforcement of foreign arbitral awards.

    UNCITRAL — Status: Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) · United Arab Emirates row · In force from 19 November 2006 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  37. UNCTAD's investment agreements database lists an Egypt-United Arab Emirates bilateral investment treaty from 1997. Investment protection between Egypt and the UAE. Entry into force date and current status not confirmed.

    UNCTAD Investment Policy Hub — Egypt - United Arab Emirates BIT (1997) · Treaty record · Checked 19 October 2026 · Research draft · Source not yet confirmed

    The UNCTAD site could not yet be checked (fetch error and proxy block); only the search result title was seen. Status, entry into force and dispute settlement terms must be confirmed.

  38. Investment projects may not be nationalised, and assets may be expropriated only for public utility with just compensation paid in advance.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Article 4 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  39. A Grievance Committee at GAFI, chaired by a judge, hears complaints about decisions under the Investment Law; grievances must be filed within 15 business days and the committee decides within 30 days after hearings close. The decision binds government bodies, but the investor may still go to court.

    General Authority for Investment and Free Zones (GAFI) / Invest in Egypt — Investment Law as enacted by Law No. 72 of 2017 (unofficial English translation) · Articles 83 and 84 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Unofficial English translation published by GAFI; the Arabic text prevails.

  40. Egypt acceded to the New York Convention on 9 March 1959, with entry into force on 7 June 1959, and no reservation is listed for it.

    United Nations Commission on International Trade Law (UNCITRAL) — Status: Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) · Egypt row · In force from 7 June 1959 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

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