{
  "url": "https://openlegislation.uk/double-taxation-relief-taxes-on-income-egypt-order-1980/note",
  "json_url": "https://openlegislation.uk/double-taxation-relief-taxes-on-income-egypt-order-1980/note.json",
  "legislation": "uksi/1980/1091",
  "legislation_title": "The Double Taxation Relief (Taxes on Income) (Egypt) Order 1980",
  "legislation_url": "https://openlegislation.uk/double-taxation-relief-taxes-on-income-egypt-order-1980",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "Under the Convention with Egypt scheduled to this Order, certain trading profits not arising through a permanent establishment, pensions (other than Government pensions) and the earnings of temporary business visitors are (subject to certain conditions) to be taxed only in the country of the taxpayer's residence. Shipping and air transport profits are to be taxed only in the country in which the place of effective management is situated. Government salaries and pensions are normally to be taxed by the paying Government only. The remuneration of visiting teachers and certain payments made to visiting students are (subject to certain conditions) to be exempt in the country visited.\nWhere income continues to be taxable in both countries, the Convention provides for relief from double taxation to be given by the country of the taxpayer's residence except where the taxpayer is a United Kingdom “Petroleum Company”. The credit to be given in the United Kingdom for tax payable in Egypt is to include credit for tax spared under certain provisions of Egyptian law.\nWhere a United Kingdom company pays a dividend to a resident of Egypt, the dividend may be taxed in the United Kingdom but the tax is limited to 20 per cent of the dividend. Where an Egyptian company pays a dividend to a resident of the United Kingdom, Egypt retains the right to impose certain taxes in full but a further tax withheld from dividends paid to individuals is limited to 20 per cent if the beneficial owner of the dividend is an individual who is a resident of the United Kingdom.\nThe rate of tax in the source country upon interest and royalties flowing to the other country is, in general, not to exceed 15 per cent. Interest on loans guaranteed by the United Kingdom ECGD will be exempt from tax in Egypt.\nThere is provision for the taxation of capital gains on immovable property and on shares in a company whose assets consist mainly of immovable property by the country in which the property is situated. Capital gains arising from the disposal of other movable property are normally to be taxed only in the country of the taxpayer's residence unless they arise from the disposal of assets of a permanent establishment or fixed base which the taxpayer has in the other country.\nThere are also provisions safeguarding nationals and enterprises of one country against discriminatory taxation in the other country and for the exchange of information and consultation between the taxation authorities of the two countries.\nThe Convention is to take effect in the United Kingdom for the tax year or financial year beginning in April 1977 and subsequent years.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/1980/1091/note",
    "retrieved_at": "2026-10-29T18:57:01.528259+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}