The Second Package of Tax Facilitations: A Practical Reading of Laws No. 148–154 of 2026

Seven laws constituting the second package of tax facilitations were published in Extraordinary Issue No. 30 (A) of the Official Gazette on July 28, 2026, and became effective as of the day following their publication.

Beyond the general headlines, these amendments do not all move in the same direction. Some simplify tax calculations, others resolve long-standing disputes or support investment, while some introduce new obligations or additional burdens on specific sectors.

Accordingly, the proper question is not simply, “Have taxes been reduced?” Rather, it is: What has changed in tax calculation methods, burden of proof, payment timing, liquidity implications, and documentation requirements for each type of activity?

First: Capital Markets — From Capital Gains Tax to Stamp Duty

Law No. 153 of 2026 imposes a stamp duty on the gross value of transactions involving securities listed on the Egyptian Stock Exchange, excluding listed investment fund units, without deducting any costs.

The tax burden is shared equally between buyer and seller:

0.5 per thousand on the buyer and 0.5 per thousand on the seller.
Reduced to 0.25 per thousand for each party for same-day buy-and-sell transactions.

The duty does not apply to transactions conducted by licensed market makers.

The settlement entity is required to withhold and remit the tax within five days from the beginning of the following month and is jointly liable with both buyer and seller for the tax and any late-payment charges.

Conversely, Law No. 151 of 2026 removes capital gains realized from the disposal of listed securities from the tax base. However, losses arising from such transactions may neither be deducted nor carried forward.

The result is a simpler taxation and collection system, although the tax applies to the transaction value regardless of whether the transaction generated a profit.

Important Note

Capital gains tax remains applicable to transactions involving listed securities where the transaction results in the delisting of the company’s shares from the stock exchange. This is a significant exception in acquisition and exit transactions.

Unlisted shares and securities remain subject to capital gains tax, whether the gains are realized in Egypt or abroad. Non-residents are required to calculate and remit the tax within sixty days of the transaction date. Gains realized by non-residents from Treasury Bills remain exempt.

Where a transaction is conducted at fair value, the acquisition cost is increased by an amount equivalent to the Central Bank’s announced lending and discount rate for each year of ownership, provided that the asset is not disposed of before three years have elapsed. Cost is calculated using the weighted-average method.

The law also waives any unpaid capital gains tax on listed shares for the period from June 16, 2023 until the effective date of the new provisions, thereby closing a transitional file that had raised practical concerns.

Second: Real Estate Disposals — The Rate Remains Fixed, but the Burden of Proof Has Changed

The tax rate remains at 2.5% of the total value of disposals of constructed real estate or land designated for construction, excluding villages, without reduction.

However, the amendments redistribute the burden of proof and introduce an important exception:

Disposal by an heir of inherited real estate, and disposal by an owner of property held for personal use, shall not be deemed a professional activity regardless of the number of transactions, unless the Tax Authority proves that the transaction was undertaken for trading and profit-making purposes under Article 19(7).
The value stated in the transfer agreement constitutes the basis for determining the total transaction value. The burden of proving otherwise rests with the Tax Authority.
A new exemption applies where real estate is contributed in kind to the capital of a joint-stock company, provided that the corresponding shares are not disposed of for five years.
The transferor must pay the tax within sixty days of the disposal date. Late-payment charges under Article 110 apply from the day following the expiry of that period.
Tax paid under these provisions is deductible from the total taxes due where Article 19(7) applies.

Third: Small Businesses — An Opportunity to Close Historical Tax Periods

The law permits the assessment of non-final taxes due from establishments and companies with annual turnover not exceeding EGP 10 million for tax periods beginning on January 1, 2022 and ending before March 2025 as follows:

0.5% of turnover for businesses with turnover of EGP 1 million to less than EGP 2 million.
0.75% for turnover of EGP 2 million to less than EGP 3 million.
1% for turnover of EGP 3 million up to EGP 10 million.
For turnover not exceeding EGP 1 million:
- EGP 1,000 annually for turnover below EGP 250,000.
- EGP 2,500 annually for turnover from EGP 250,000 to less than EGP 500,000.
- EGP 5,000 annually for turnover from EGP 500,000 to less than EGP 1 million.

Two Conditions

The assessment may not be lower than the tax amounts reported in the taxpayer’s returns.
Taxpayers retain the right to choose taxation under the ordinary provisions of the Income Tax Law.

The advantage is not necessarily that the simplified system is always better, but that it offers a mechanism for closing old tax periods before transitioning to the system established under Law No. 6 of 2025. In some cases, ordinary taxation may be less burdensome, making comparative calculations essential before making a choice.

Fourth: Tax Disputes — A Window Open Until December 31, 2026

The application of Law No. 79 of 2016 concerning the settlement of tax disputes has been extended until December 31, 2026.

Committees will continue examining unresolved applications and will also consider new applications submitted until the same date.

This is one of the provisions requiring immediate attention. The law does not automatically settle disputes; it merely opens a window for filing settlement requests. Companies and professional offices with ongoing disputes should inventory and evaluate their cases promptly before the deadline expires.

Fifth: Value Added Tax (VAT) — Support for Manufacturing and the Medical Sector with Documentary Conditions

A 5% VAT rate applies to machinery, equipment, and medical devices used in producing goods or providing services, excluding buses and passenger vehicles.
Tax payment is suspended on imported or locally purchased machinery, equipment, and medical devices used by factories and production units for industrial manufacturing for one year from customs clearance or purchase. This period may be extended for justified reasons accepted by the Tax Authority, up to a maximum total period of three years. Exemption applies upon proof of actual use.
Failure to use the assets within the permitted period results in VAT and additional tax becoming payable from the customs clearance or purchase date until payment.
Following exemption, disposal of such assets for non-exempt purposes is prohibited for five years unless the Tax Authority is notified and the applicable tax is paid.
A direct liquidity benefit is introduced through the refund of VAT credit balances that have remained outstanding for more than four consecutive tax periods. For businesses covered by Law No. 6 of 2025 with annual turnover not exceeding EGP 20 million, the period is reduced to more than three months.
Natural gas is no longer exempt and becomes subject to a schedule tax of EGP 20 per 1,000 cubic feet. The exemption is limited to butane gas (LPG).
Exemptions are expanded to include non-banking financial services regulated by the Financial Regulatory Authority or the Central Bank, as well as postal savings banking services.

Sixth: A Point That May Go Unnoticed — Leasing of Premises

The sale and lease of vacant land, agricultural land, residential buildings, and residential units remain exempt.

The sale and lease of non-residential buildings and units also remain exempt, except where the premises are used as an independent headquarters for managing a business activity, even if they have a commercial nature and customer interaction.

Exceptions continue to apply to premises used for religious, charitable, social, educational, and healthcare activities, as well as any other activities designated by ministerial decision for public-interest social reasons.

This issue affects not only landlords but also tenants, contract pricing, whether the rent is VAT-inclusive, invoicing timing, and the tenant’s right to input tax deduction.

Seventh: Technical Amendments with Direct Impact on Financial Statements and Settlements

Bad Debts: Debts not exceeding EGP 10,000 per debt are exempt from the requirement to undertake serious collection procedures, provided total bad debts do not exceed 1% of total receivables at year-end.
Solidarity Contribution: The Universal Health Insurance solidarity contribution becomes a deductible expense.
Intercompany Dividends: Dividends received by a parent or holding company from resident or non-resident subsidiaries are excluded from taxation, provided ownership or voting rights are at least 25% and held for at least two years, or there is a commitment to maintain such ownership for two years.
Infrastructure Financing: The cap on deductible interest expense is increased to four times average equity. Interest on loans and facilities obtained from unrelated parties may be exempt, subject to conditions including a minimum company contribution of 25% of total project investment and a minimum financing term of five years.
Stock Exchange Listing Incentive: A deduction equal to 15% of tax due under the tax return is granted for three years from the date of listing, provided the market value at listing is at least EGP 50 billion and at least 20% of shares are offered, or shares worth at least EGP 10 billion are offered. The incentive is available only once during the company’s lifetime and may not be combined with other tax incentives.

Eighth: On the Other Hand — New Obligations and Burdens

Not everything introduced under this package can be described as a facilitation:

Departure tax has increased to EGP 100, with exemptions for public passenger and freight transport drivers regularly crossing borders.
The cement levy becomes EGP 35 per ton produced, payable by manufacturers to the Egyptian Tax Authority.
The Unified Tax Procedures Law confirms the obligation of all taxpayers engaged in commercial, industrial, professional, or craft activities to maintain regular accounting books and records, whether manually or electronically.
A temporary tax card valid for eight months may be issued for incorporation and licensing procedures, but it cannot be used for issuing electronic invoices or receipts.
Under Law No. 154 of 2026, companies wholly owned by the state or public legal entities must allocate 5% of distributable net profits, while companies in which state ownership exceeds 50% must allocate 4%. These amounts are treated as tax revenues payable to the state treasury within four months of the financial year-end.

Conclusion

The second package should not be viewed as a single piece of news but rather as a map of decisions and implications.

Stock market investors, real estate developers, manufacturers, hospitals, landlords, small businesses, and holding companies will each experience different impacts and compliance requirements.

The greatest mistake during the coming period would be to wait until filing a tax return or undergoing a tax audit. What is required now is a review of contracts, pricing models, accounting policies, fixed-asset records, and dispute files, followed by translating the new legal provisions into practical internal procedure

The Second Package of Tax Facilitations: A Practical Reading of Laws No. 148–154 of 2026