Transfer Pricing & Pillar Two
Expert transfer-pricing documentation, benchmarking, and Pillar Two impact assessments to protect your group from cross-border tax disputes and new global minimum-tax obligations.
Transfer pricing has become one of the most scrutinised areas in international tax. Egypt's Executive Regulations under the Income Tax Law require related-party transactions to be priced on arm's-length terms and documented in a contemporaneous Transfer Pricing Master File and Local File. ETAF Office provides the technical expertise to meet these obligations and defend your group's intercompany pricing before the Egyptian Tax Authority.
We conduct economic analyses and functional analyses to identify the most appropriate transfer-pricing method (CUP, cost-plus, TNMM, profit split) for each category of intercompany transaction — loans, management fees, royalties, services, and tangible goods. Our benchmarking studies use recognised commercial databases to identify comparable independent transactions that support your pricing policy.
On Pillar Two, the OECD's Global Anti-Base Erosion (GloBE) rules introduce a 15% global minimum tax for multinational groups with consolidated revenues exceeding €750 million. We help Egyptian-based multinationals and inbound investors assess their Pillar Two exposure, model the top-up tax liability, and implement the required documentation and data-collection processes.
- Transfer pricing policy design and implementation
- Master File and Local File preparation (OECD BEPS Action 13)
- Country-by-Country Reporting (CbCR) support
- Benchmarking studies using commercial databases
- Pillar Two GloBE impact assessment and modelling
- Advance Pricing Agreement (APA) support
What's Included
How It Works
Group Structure & Transaction Mapping
We map all intercompany transactions within your group, identifying the counterparties, volumes, and transaction types (goods, services, IP, financing).
Functional & Risk Analysis
We conduct a detailed functional analysis of each entity — identifying functions performed, assets used, and risks assumed — to determine the appropriate characterisation and pricing method.
Benchmarking Study
We search commercial databases to identify independent comparable companies or transactions, applying statistical filters to arrive at an arm's-length range.
Documentation Preparation
We prepare the Master File, Local File, and CbCR notifications in compliance with Egyptian regulations and OECD guidelines, ready for submission to the ETA if requested.
Pillar Two Assessment
For qualifying multinationals, we model the GloBE effective tax rate by jurisdiction, identify top-up tax exposures, and advise on mitigation strategies and required disclosures.