We help design and implement Global TP Policy / review Agreements for Multinational Corporations. We also provide Transfer Pricing litigation support services.
Transfer Pricing compliance requirements by delivering meticulously prepared Documentation as per Local TP Regulations and global standards.
We assist in identifying gaps by providing health check up from Legal, Corporate and TP documentation perspective.
We have access to various public financial and company databases, industry and directories which assist us to render comprehensive TP analysis.
In July 2016, Egypt became a member of the Inclusive Framework on BEPS, which brings together over 135 countries and jurisdictions on an equal footing to tackle tax avoidance. The CbC reporting requirements under BEPS Action 13 form one of the four BEPS minimum standards. The thresholds for CbCR have been set out in the ETPG:
A constituent entity of an MNE group that is a tax resident in Egypt will need to notify the ETA whether it is the ultimate parent entity or not. If the Egypt tax resident constituent entity is not acting as an ultimate parent entity, it shall file a notification with the ETA containing the identity and tax residence of the ultimate parent entity and the reporting entity of the group, in accordance with the CbC notification form.
The CbCR should be submitted to the ETA no later than one year after the end of the fiscal year in concern and the CbCR notification form should be submitted before the end of the fiscal year to which the report relates.
The CbCR filing requirements apply for fiscal years ending on or after 31 December 2018. Hence, the first CbC reports should be filed by 31 December 2019.
Leader - Gulf Practice
20+ years, experience in International Tax and Transfer Pricing space.
Worked with A.F. Fergusson, KPMG, Ernst & Young and Deloitte wherein he served numerous Fortune 500 clients in different business space like consumer goods, automotive, IT and ITES. He did his masters in Law with Mumbai University and was part of the Tax Controversy Management Team at Deloitte.