A three-tiered transfer pricing documentation to be submitted before the Egyptian Tax Authority (ETA) relating to the following:
- Local File (‘LF’): provides detailed information relating to the transactions of a local taxpayer with its AEs, relating to details of the local entity and analysis of the transactions, determination and following the principle of the arm’s length price and principle.
- Master File (‘MF’): providing an overview of the international group business, including information on the nature of its global business operations, its transfer pricing policies, and its global allocation of income and economic activity which include various factors such as Organization structure, financial arrangements, and financial positions, etc.
- Country by Country Report (‘CbCR’): providing jurisdiction-wide information regarding the international group’s global allocation of income, taxes paid, and the location of key economic activity where the group operates.
- CbCR Notification: If the Egyptian tax resident constituent entity is not the ultimate parent entity of the group or is acting as the alternate reporting entity for filing CbCR, it is required to file a notification with the ETA containing the identity and tax residence of the ultimate parent entity (or the alternate reporting entity) in accordance with the CbC Reporting notification form applicable in Egypt.
