DT6452 - Double Taxation Relief Manual: Guidance by country: Egypt: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Egypt is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject	Comments	Article
Portfolio dividends	0%/20%/no limit (Note 1)	10
Dividends on direct investments	20% (Note 1)	10
Conditions for lower rate on dividends on direct investments	N/A	N/A
Property income dividends	0%/20%/no limit (Note 1)	10
Interest	15% (Note 2)	11
Royalties	15%	12
Government pensions	Taxable only in Egypt unless the individual is a UK national without also being an Egyptian national	19
Other pensions	Taxable only in the UK	18
Arbitration	No	N/A

Note 1: If the dividend paid by the Egyptian company is deductible in determining that company’s taxable profits, then the dividend is taxable up to 20% if the UK recipient is an individual. If the recipient is not an individual, there is no limit on the taxation Egypt may apply.

If the dividend is not deductible from the amount of taxable profits of the Egyptian payer, then the dividend is taxable only in the UK.

Note 2: Interest paid in respect of a loan made, guaranteed or insured by the UK Export Credits Guarantee Department is exempted from Egyptian tax, or if the interest is beneficially owned by the UK Government.