DT6453 - Double Taxation Relief Manual: Guidance by country: Egypt: Notes

Students (Article 20)

Visiting students, research workers and trainees from Egypt are exempted from UK tax on payments from abroad for the purpose of their maintenance, education or training, on certain grants and awards and, in certain circumstances, on their earnings in the UK.

Exemption is not given on remuneration which a student earns in the UK as an articled clerk or for services rendered to the person who is providing their training.

The exemption is available a period of up to five years.

Teachers (Article 21)

An individual who visits the UK for a period not exceeding two years for the purpose of teaching or engaging in research at a university, college or other recognised educational institution in the UK, and who was immediately before that visit a resident of Egypt, shall be exempted from tax in the UK on any remuneration for such teaching or research for a period not exceeding two years from the date they first visit the UK for such purpose.

This only applies to income from research that is undertaken in the public interest and not primarily for the benefit of some other private person.

Tax spared (Article 22)

The convention provides for credit to be given for tax ‘spared’ (see INTM161270 - 161290) in Egypt under those provisions of Egyptian law which are set out in Article 22(3). The modification of Article 16 of Law No.43 of 1974 by Law No.32 of 1977 does not affect the entitlement to credit for tax ‘spared’ under the original law as so modified.

The following Articles are agreed to be substantially similar to Article 16 of Law No.43 of 1974 such that the provisions of paragraph 3 of Article 22 apply by virtue of sub-paragraph 3(b):

  • the Law No. 59 of 1979
  • Article 11 of Law No. 230 of 1989
  • Article 16 of Law No. 8 of 1997

Credit may also be given for tax spared under these laws.

Relief is restricted to tax spared in Egypt for a period of ten years in respect of any one source of income. Amounts of tax spared for which credit relief is given should be reported as mentioned in INTM161290.