Beta Version

Website Last updated:

June 26, 2026

This comprehensive Double Taxation Agreement (DTAA) between the United Arab Emirates and Egypt updates their bilateral tax framework to prevent double taxation and eliminate treaty-shopping abuses. Signed in November 2019, it establishes clear residency tie-breaker rules and sets Permanent Establishment thresholds at 6 months for construction and 183 days for services. Under the treaty, withholding tax on dividends is capped at 5% for substantial corporate holdings (at least 10% capital) and 10% for all other cases, while interest and royalties are capped at 10%. It also features dedicated clauses for hydrocarbons and grants tax exemptions for sovereign government investment income.

Agreement between the Government of the UNITED ARAB EMIRATES and the Government of the ARAB REPUBLIC OF EGYPT Regarding the Avoidance of Double Taxation and the Prevention of Tax Evasion with respect to Taxes on Income

StatusIn Force

Signed on14 November 2019

Entered into force19 April 2021

Amended on-

Terminated on-

The Government of the United Arab Emirates and the Government of the Arab Republic of Egypt,

Desiring to further develop their economic relationship and enhance their cooperation in tax matters,

Desiring to conclude an Agreement for the elimination of double taxation with respect to the taxes covered by this Agreement without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third States),

Have agreed as follows:

Contents

CHAPTER I - SCOPE OF THE AGREEMENT

Article 1 - Personal Scope

Article 2 - Taxes Covered

CHAPTER II - DEFINITIONS

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

CHAPTER III - TAXATION OF INCOME

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Independent Personal Services

Article 15 - Dependent Personal Services

Article 16 - Directors' Fees

Article 17 - Artistes and Sports persons

Article 18 - Pensions and Annuities

Article 19 - Government Service

Article 20 - Students and Trainees

Article 21 - Professors, Teachers, and Researchers

Article 22 - Hydrocarbons

Article 23 - Other Income

Article 24 - Income of Government and its Institutions

CHAPTER V - METHODS FOR ELIMINATION OF DOUBLE TAXATION

Article 25 - Elimination of Double Taxation

CHAPTER VI - SPECIAL PROVISIONS

Article 26 - Non-Discrimination

Article 27 - Mutual Agreement Procedure

Article 28 - Exchange of Information

Article 29 - Members of Diplomatic Missions and Consular Posts

Article 30 - Anti-Abuse

CHAPTER VII - FINAL PROVISIONS

Article 31 - Entry into Force

Article 32 - Termination

Protocol

CHAPTER I - SCOPE OF THE AGREEMENT

Article 1
Personal Scope

This Agreement shall apply to persons who are residents of one or both of the Contracting States.

Article 2
Taxes Covered

This is an unofficial / best effort translation

CHAPTER I - SCOPE OF THE AGREEMENT

Article 1Personal Scope

Article 2Taxes Covered

Article 1
Personal Scope

Article 2
Taxes Covered