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12.4.4. APAs and Dispute Resolution Mechanisms


Effective from 22 May 2018, taxpayers are allowed to enter into an advance pricing agreement with the tax authority on the method applied for a transaction. The updated transfer pricing guidelines include guidance on the procedures for Egypt's APA program (which is currently limited to unilateral APAs), including the types and benefits of APAs, the application and processing, compliance, and the application form templates.


If an adjustment is proposed by the tax authority, the taxpayer has the right to appeal through the same appeals process for other tax adjustments/assessments (see Sec. 13.7.).