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House approves tax exemptions for UAE sovereign fund
To pave the way for more Emirati investments and secure the capital return on those already made in Egypt, the House of Representatives approved on Sunday a supplementary protocol to the Egyptian-United Arab Emirates tax agreement, granting the Emirati sovereign wealth fund a tax exemption in Egypt.
The annex, issued by presidential decree earlier this year, recognizes Egypt's Sovereign Fund and UAE's Abu Dhabi Development Holding Company (ADQ) as 'government institutions' and consequently allows both funds to benefit 'from the tax exemptions stipulated in the agreement.'
Upon their approved recognition in the agreement as government bodies, both funds are subject to Article 24, which grants tax exemptions on income generated by the government as well as its affiliated bodies, according to a joint report issued by the House planning and budgeting and Arab affairs committees and reviewed by Mada Masr.
The agreement with the UAE, aimed at enhancing investment and trade relations between both countries, was initially approved by President Abdel Fattah al-Sisi in November 2019, under the Presidential Decree 558 of 2020.
Emirati investments are crucial for Egypt at a time when the country's economy is deeply affected by Israel's aggression on Gaza and more recent attacks on Iran.
Last year alone, ADQ, the Gulf country's largest sovereign fund, invested US$35 billion through the Ras al-Hikma development project in the North Coast. Half of the mega deal's proceeds were allocated at the time to easing the country's growing public debt. ADQ also acquired stakes in three state-owned petroleum companies for $800 million in November last year.
Under Article 24's second section, the term 'government' includes 'the government, its agencies and institutions […] as well as any other institution or body mutually agreed upon from time to time by the governments of the two contracting states.'
In the past, Egypt signed 60 similar agreements with other countries, some dating as far back as the 1970s, a Finance Ministry official told Mada Masr on condition of anonymity. These agreements are periodically reviewed and re-negotiated by both parties, the official said. When amendments are limited to one or two provisions, they said, they are issued in the form of a protocol and appended to the original agreement.
In this case, the protocol was necessary because the original tax agreement was finalized in 2017, before either the Egyptian or Emirati sovereign wealth funds were established.
Agreements to avoid double taxation typically require that the benefitting entities be explicitly named. According to the official, the supplementary protocol was added after it became clear during ADQ's financial dealings that the fund was not listed among the beneficiaries of the agreement, as it had not been named or specified in the original text.
The exemptions outlined in Article 24 include taxes on three types of income: dividends, capital gain, and interest, a source in the House Planning and Budgeting Committee told Mada Masr. The interest exemption applies to all forms of government lending instruments, such as bonds, sukuks and deposits, among others.
Upon the maturity of the financial instrument, the lender or investor receives the principal amount along with interest — or what is considered profit — from which the Finance Ministry deducts a 20 percent tax, as stipulated in the Income Tax Law, which applies to both Egyptians and non-Egyptians.
While the government continues to offer incentives, including tax exemptions, to encourage Emirati investment in the domestic economy, it has been less forthcoming with other international entities.
In November 2023, Euroclear, a platform for settling securities transactions that Egypt had hoped to join, requested a tax exemption on treasury bills and bonds as a condition for granting access to the government's debt market. The Egyptian government has yet to respond to the request.
