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Question Egypt - taxation of foreign sourced income

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Bagpacker

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Has anybody ever looked a bit deeper into the current Egyptian taxation system for private individuals?
I am specifically asking regarding foreign sourced taxation of capital gains, dividends and interest.

In the Good Old Days about 10 years ago the answer was clear-cut (extract from an FAQ published by the Ministry of Finance of Egypt in 2008): "The law apply the tax regionalism principle for the normal individuals, so that the tax is only imposed on their net income realized inside Egypt, ...". It was indeed a paradise back then.
They changed that law in 2014 and the situation has become a bit unclear nowadays.
KPMG says in its latest but slightly outdated "Egypt Income Tax Guide" (dated 01-January-2017) that "Foreign-sourced income is not subject to individual income tax in Egypt provided Egypt is not the centre of their commercial or industrial or professional activities."
PWC says in its new "Egypt Overview / Income Determination" (dated 28-February-2021): "Capital gains realised from shares invested abroad would be subject to the individual income tax brackets (if Egypt is the centre of commercial industrial or professional activity of such individual)."
Has anybody any practical experience how the Egyptian taxman classifies "foreign-sourced-income" and how he defines "commercial, industrial or professional activities"?

The current legislation provides for a 10% tax on capital gains of stocks listed on Egyptian Stock Exchange, even though this tax has been suspended until the end of 2021 (Law 199 of 2020). I find it hard to believe that they only tax gains from stocks listed on their own stock exchange and let foreign gains on stocks go untaxed.

Any thoughts or practical experience is highly appreciated.
 
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