Egypt's Tax Authority has released the full text of three newly enacted laws that form the backbone of its sweeping tax facilitation initiative, part of a broader effort to modernize the system, ease compliance burdens, and draw more individuals and businesses into the formal economy. An English-language version of the laws, published in the latest issue of Amwal Al Ghad Magazine, offers wider access to the legal framework behind Egypt's reform drive. The legislation introduces reduced penalties, streamlined settlement procedures, and simplified tax structures for small enterprises—key elements in the government's push to rebuild trust with taxpayers and improve fiscal sustainability. Law No. 5 of 2025 Concerning the Regularisation of the Status of Certain Taxpayers and Liable Persons In the Name of the People The President of the Republic The House of Representatives has approved the following law, which we hereby promulgate: Article (1) For the purposes of this law, the following terms and expressions shall have the meanings specified next to each: 1. The Authority: The Egyptian Tax Authority. 2. Tax Law: The Income Tax Law, the Value Added Tax (VAT) Law, the Financial Resource Development Levy Law, or the Stamp Duty Law. Article (2) Tax assessments, whether for income tax, value-added tax, stamp duty, or the financial resource development levy, shall not be conducted for individuals or entities not registered with the Egyptian Tax Authority for tax periods prior to the date this law comes into effect. The effective date of this law shall be considered the commencement date for activity under the provisions of the Income Tax Law No. 91 of 2005 and the Value Added Tax Law No. 67 of 2016. The application of the first paragraph of this article is subject to the following conditions: 1. A registration request must be submitted for income tax and value-added tax, in accordance with the legal requirements for mandatory registration, within three months from the date this law comes into effect. The Minister of Finance may extend this period once. 2. No action has been taken by the Authority against the registration applicant before the effective date of this law. 3. All necessary documentation for registration must be submitted to all of the Authority's electronic systems, in accordance with the phased compliance process. Article (3) Taxpayers or liable persons who have failed to submit their declarations for any tax period from 2020 onwards, up to the periods preceding the effective date of this law, shall have the right to submit these declarations. These declarations shall include all legally required forms, including the documents outlined in Article (12) of the Unified Tax Procedures Law, issued under Law No. 206 of 2020. Taxpayers or liable persons who have submitted their tax declarations for the periods mentioned in the first paragraph of this article shall have the right to submit amended tax declarations in the event of omissions, errors, or unreported data, without incurring any delay penalties or additional taxes for the period between the submission of the original declarations and the amended declarations. The provisions of the second paragraph of this article shall apply to amended tax declarations submitted after the prescribed deadlines, prior to the effective date of this law. For the purposes of this article, no penalties outlined in the Unified Tax Procedures Law, nor any financial penalties imposed under other tax laws, shall apply, provided that the returns referred to in the first and second paragraphs of this article are submitted within six months from the effective date of this law. Article (4) Taxpayers or liable persons who have been subjected to an estimated tax examination for tax periods ending before January 1, 2020, may request the resolution of disputes related to these periods, which are under consideration at any stage of the dispute process, in accordance with the following: 1. Payment of a tax amount equal to (30%) of the tax due, based on the declaration submitted by the taxpayer or liable person for each disputed tax period, without affecting the payment of the tax due as per the declaration. 2. Payment of a tax amount equal to the tax due, based on the latest agreement for the disputed period or periods, plus (40%), in the following cases: (a) Failure to submit a tax declaration for the disputed period or periods. (b) Submission of a tax declaration for the disputed period or periods showing no tax due. (c) Submission of a tax declaration for the disputed period or periods resulting in tax losses. The taxpayer or liable person may pay the tax due, along with any delay penalties or additional taxes, in installments, as follows: o (25%) within three months from the date of notification with the payment form. o (25%) within the three months following the period specified in paragraph (1). o (25%) within the three months following the period specified in paragraph (2). o (25%) within the three months following the period specified in paragraph (3). All of the above without any delay penalties or additional taxes being imposed on these installments. Article (5) Taxpayers or liable persons who have been subjected to an assessment by the tax authority for tax periods ending before January 1, 2020, based on regular books and records, may request the resolution of disputes concerning these periods. These disputes, which are under review at any stage of the dispute process, may be resolved in exchange for the full waiver of (100%) of the delay penalties, additional taxes, and supplementary amounts. This is provided that the taxpayer or liable person settles the full principal tax debt within three months from the date of submitting the dispute resolution request. Article (6) Taxpayers or liable persons wishing to benefit from the provisions of Articles (4) and (5) of this law are required to submit a request to the Authority for dispute resolution within three months from the date this law comes into effect. The request must include the taxpayer's or liable person's name, registration number, case or appeal number, types of taxes, the disputed periods to be resolved in accordance with the provisions of these articles, and any other necessary information on the prescribed form. Upon receiving and registering the request, the Authority must notify the clerk of the competent court or the secretary of the appeals committee or the internal committee as outlined in the Unified Tax Procedures Law, of the dispute resolution request within thirty days from the date of submission. The court clerk or committee secretary is required to present this notification to the head of the court or the head of the committee, as applicable, within five working days from receipt. As a result of the notification referred to in the first paragraph of this article, the dispute will be suspended by operation of law for a period of three months, beginning the day following the expiration of the five-day period mentioned above. Furthermore, upon the notification of the relevant committee or court regarding the payment of the due tax in accordance with the provisions of Articles (4) and (5) of this law, the dispute will be considered legally resolved. The Minister of Finance may, through a ministerial decision, extend the period specified in the first paragraph of this article for an additional similar period. Article (7) Natural persons who have carried out a real estate transaction or a transaction involving unlisted securities during the five years prior to the effective date of this law, and who are not engaged in other activities subject to income tax, may request to be assessed for tax on the real estate transaction or capital gains tax on the transaction involving unlisted securities, as applicable. Payment of the due tax within six months from the effective date of this law will result in a (100%) waiver of any late payment penalties. In all cases, the Authority shall not assess any transactions referred to in the first paragraph of this article if five years have passed since the transaction. Natural persons mentioned in the first paragraph of this article may submit a request to the Authority to resolve any existing disputes concerning the tax on real estate transactions or capital gains tax on transactions involving unlisted securities at any stage of the dispute. This request must be submitted on the prescribed form, along with payment of the due tax on the transaction, within three months of submitting the dispute resolution request. As a result, the (100%) waiver of late payment penalties will apply. The timelines, procedures, and provisions specified in Article (6) of this law shall apply to this request. Article (8) In all cases, the resolution of a dispute between the taxpayer or the obligated party and the Authority in accordance with the provisions of this law shall not entitle the taxpayer or the obligated party to reclaim any amounts previously paid. Article (9) The head of the Authority shall issue a decision to determine the application forms referred to in Articles (4), (5), (6), and (7) of this law. Article (10) The Minister of Finance shall issue the necessary decisions to implement the provisions of this law within one month from its effective date. Article (11) This law shall be published in the Official Gazette and shall take effect on the day following its publication. It shall be stamped with the State Seal and shall be enforced as a law of the Republic. Issued by the Presidency of the Republic on the 13th of Sha'ban, 1446 AH (Corresponding to the 12th of February, 2025 AD). Abdel Fattah El-Sisi Law No. 6 of 2025 On Certain Tax Incentives and Facilities for Projects with Annual Turnover Not Exceeding EGP 20 Million In the name of the people The President of the Republic The House of Representatives has passed the following law, which we hereby issue: Chapter One Definitions and General Provisions Article (1) For the application of this law, the following terms and expressions shall have the meanings assigned to each: 1. Projects subject to this law: Projects with an annual turnover not exceeding EGP 20 million, seeking to benefit from the provisions of this law, including professional activities, whether already tax-registered on the date this law enters into force or not. 2. The Authority: The Egyptian Tax Authority. 3. Tax Law: The Income Tax Law or the Value Added Tax Law. Article (2) Without prejudice to the rules and procedures set out in the tax law, the turnover of a project subject to this law shall be determined based on any of the following criteria: 1. Data from the most recent final tax assessment for the project registered with the Authority at the date of this law's entry into force. 2. Data from the most recent tax return submitted by the registered project, if not yet assessed by that date. 3. Data from the tax return submitted by a project registering after the law's entry into force. 4. Available data from the e-invoice or e-receipt systems. Article (3) To benefit from the tax incentives and facilities under this law, the following conditions must be met: 1. Timely submission of the tax returns referred to in Article (12) of this law. 2. Enrollment in the Authority's digital systems, including e-invoicing and e-receipts, according to the enforcement phases determined by the Authority's head, and issuance of the required invoices or receipts. Article (4) This law does not apply to the following cases: 1. Professional consultancy activities deriving at least 90 per cent of their annual turnover from one or two clients. 2. Projects engaging in acts or behaviour intended to unjustifiably fall within the scope of this law, including splitting or segmenting activities without an economic rationale. The burden of proof lies with the Authority. The Minister of Finance may, by decree, exempt certain activities from paragraph (1) of this article. Article (5) Projects subject to this law may not revoke their request to benefit from its provisions before five years have passed from the day following the submission date of the request. Article (6) In the absence of specific provisions in this law, the provisions of the tax law or the Unified Tax Procedures Law No. 206 of 2020 shall apply, as the case may be. Chapter Two Tax Incentives Article (7) Projects subject to the provisions of this law shall be exempt from the state's financial resources development fee, the stamp duty, and the notarisation and registration fees for company and establishment incorporation contracts, credit facility and mortgage contracts related to their operations, and other guarantees provided to obtain financing. Additionally, land registration contracts required for the establishment of such projects shall also be exempt from the aforementioned taxes and fees. Article (8) Capital gains from the disposal of fixed assets, machinery, or production equipment by projects subject to this law shall be exempt from the corresponding tax. Article (9) Dividend distributions arising from the activities of projects subject to this law shall not be subject to dividend tax under the income tax law. Article (10) Income tax on projects under this law shall be calculated as follows: 1. (4) per cent of turnover for projects with annual turnover under EGP 500,000 2. (5) per cent for turnover between EGP 500,000 and less than EGP 2 million 3. (75) per cent for turnover between EGP 2 million and less than EGP 3 million 4. (1) per cent for turnover between EGP 3 million and less than EGP 10 million 5. (5) per cent for turnover between EGP 10 million and not exceeding EGP 20 million If the project's annual turnover exceeds twenty million Egyptian pounds in any year within five years from the date of applying to benefit from the provisions of this law, by no more than 20 per cent and for one time only, the project shall continue to benefit from these provisions according to the tax rate stipulated in item (5) of this article. However, if the annual turnover exceeds this percentage or if the excess occurs more than once during the mentioned period, the project's eligibility for the benefits of this law shall end starting from the following year. Chapter Three Tax Facilities Article (11) Projects subject to this law are not required to adhere to the advance payment or withholding systems under Income Tax Law No. 91 of 2005. Article (12) Projects subject to the provisions of this law shall have a separate annual tax return form for their commercial, industrial, or professional activity. This form shall be determined by a decision issued by the Minister of Finance based on a proposal from the Head of the Tax Authority and shall be submitted within the same deadlines specified in the aforementioned Unified Tax Procedures Law. As for the value-added tax (VAT) return, it shall be submitted every three months using the designated form during the month following the end of each period, accompanied by the payment of the tax. The obligation of projects subject to this law regarding the payroll tax and its equivalents shall be limited to submitting the annual tax reconciliation return specified in the aforementioned Unified Tax Procedures Law, accompanied by the payment of the tax. The tax returns of projects subject to the provisions of this law shall be examined after the lapse of five years from the date of applying to benefit from the provisions of this law, with respect to both income tax and value-added tax. Article (13) Projects subject to the provisions of this law shall be exempt from keeping the records, books, and documents stipulated in the aforementioned Unified Tax Procedures Law. Instead, they shall be required to comply with the simplified systems for records, books, documents, and procedures as determined by a decree issued by the Minister of Finance based on a proposal from the Head of the Tax Authority. Chapter Four Final Provisions Article (14) The Minister of Finance shall issue the necessary regulations to implement this law within one month from its enforcement date. Article (15) Articles 85, 86, 87, 93, 94, 95, 96, 97, 98, and 99 of Law No. 152 of 2020 on the Development of Medium, Small, and Micro Enterprises are hereby repealed. Article (16) This law shall be published in the Official Gazette and come into force on the first day of the month following its publication. It shall bear the seal of the state and be enforced as one of its laws. Issued by the Presidency of the Republic on Shaaban 13, 1446 AH (corresponding to February 12, 2025 AD) Abdel Fattah El Sisi
Law No. 7 of 2025 Amending Certain Provisions of the Unified Tax Procedures Law No. 206 of 2020 In the name of the people The President of the Republic The House of Representatives has passed the following law, which we hereby issue: Article One New articles (45 bis, 75 bis, 75 bis 1) are added to the Unified Tax Procedures Law No. 206 of 2020, as follows: Article (45 bis): Under tax laws, late fees or additional tax may not exceed 100 per cent of the original tax amount. Article (75 bis): The Minister or his delegate may settle offences stipulated in this law or the tax law, provided they do not involve tax dues, in exchange for the payment of compensation not less than half the minimum prescribed fine and not exceeding twice that minimum. This settlement must occur before criminal proceedings are initiated. The right to settlement shall not lapse upon the initiation of criminal proceedings if compensation equal to the minimum prescribed fine, and not exceeding three times that amount, is paid before a judgment on the merits is issued. If a final judgment is issued, settlement may still be made in return for payment of compensation equal to four times the minimum fine and not exceeding its maximum. In all cases, payment shall be made to the treasury of the Tax Authority or to a person authorised by the Minister to receive it. Article (75 bis 1): The Minister or delegate may settle the offence stated in Article (135) of the Income Tax Law No. 91 of 2005 by collecting: 1. Compensation equal to 12.5 per cent of unwithheld/undeducted/collected amounts. 2. Compensation equal to 12.5 per cent of withheld/deducted/collected but unremitted amounts, plus the original amount and late fees. Article Two This law shall be published in the Official Gazette and come into force the day after its publication. It shall bear the seal of the state and be enforced as one of its laws. Issued by the Presidency of the Republic on Shaaban 13, 1446 AH (corresponding to February 12, 2025 AD) Abdel Fattah El Sisi
