Tax Law and International Tax Law

The Egyptian tax system has undergone a significant change following the enactment of Law No. 151 of 2026, amending certain provisions of the Income Tax Law No. 91 of 2005. Article 6 of the new law repealed Article 18 of the Income Tax Law, which had provided the legislative basis for issuing specific rules and principles for the tax assessment of small enterprises.

Changes in business models and supply chains have become increasingly common as multinational groups respond to cost pressures, digitalization, geopolitical developments, market expansion, and the need for greater supply-chain resilience. While these changes are usually driven by commercial considerations, they can significantly affect a group’s transfer pricing position.

Debt-to-equity conversion is considered one of the most important financial restructuring tools used by companies to address financing structure imbalances and improve their financial position. The importance of this mechanism is particularly evident in cases where companies rely on debt financing for extended periods, whether through shareholders’ loans, loans provided by subsidiaries or sister companies, or external financing, resulting in a high level of liabilities compared to equity.