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3.1. Corporate Tax Residence

A company is deemed resident in Egypt if it is incorporated under Egyptian law, or if it has in Egypt its central or effective management. Central or effective management is deemed to be in Egypt if 2 or more of the following 5 criteria are satisfied:

  • Daily management decisions are taken in Egypt;
  • Board or management meetings are held in Egypt;
  • 50% or more of the managers or partners are resident in Egypt;
  • 50% or more of the capital is held by residents; or
  • An interest of 50% or more is held in the entity by the State or State-owned entities.