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12.3.1. Main Rules

Under the following conditions, an Egyptian resident company will be required to pay corporate income tax on its share of a controlled foreign company's (CFC) income:

  • The Egyptian resident company's ownership in the CFC exceeds 10%
  • More than 70% of the CFCs income is comprised of dividend, interest or royalties income, or management or rental fees
  • The CFC income is not subject to tax where it is registered or the income tax rate of the country does not exceed 75% of the Egyptian income tax rate