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HMRC internal manual

Double Taxation Relief Manual

Egypt: Tax spared

The agreement 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 and Article 16 of Law No. 8 of 1997 and 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.