Egypt

Branches of foreign corporations operating in Egypt receive tax treatment identical to that of corporate entities for the results of their activities in Egypt.

A branch, but not a subsidiary, may deduct a 'head office charge' of an amount of up to 10% of its taxable income.

According to Law No. 53 of 2014, a PE’s profits that are not remitted (repatriated) within 60 days of the following financial year-end may be deemed as dividend payments to the head office (and thus subject to 10% WHT under Law No. 199 of 2020, as updated from the previous 5% rate).