Treaty detail
United States - Egypt tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1980-08-24
Effective
1982-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The 5 percent corporate rate generally depends on direct ownership of at least 10 percent of the voting stock of the dividend payer. The older treaty wording and Egyptian domestic withholding rules can change the practical result, so article-level review is essential.
Interest
Rate: 15%
IRS Treaty Table 1 reflects a general 15 percent ceiling on qualifying interest, with government and similar exemptions available subject to article-level review.
Royalties
Rate: 15%
The Egypt treaty applies a relatively high 15 percent royalty ceiling on most categories, reflecting its older 1980 drafting. Article-level review remains important for software and know-how classification.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis under the older 1980 wording can be triggered by stock-of-merchandise and agency rules that are narrower than modern OECD-style treaties.
Other treaty flags
Pension treatment is article-specific under the 1980 treaty, with government-service pensions and private pensions handled under distinct provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to reduced withholding or treaty protection.
Residence under the Egypt treaty matters particularly for U.S. consultants on government and infrastructure projects. The 1980 treaty drafting uses tie-breaker rules that broadly parallel modern OECD-style treaties but should be read against the article text.
Article 5
Permanent Establishment
Sets the business-presence threshold that permits source-country taxation of business profits.
The Egypt treaty includes a six-month threshold for construction and installation projects and a service-PE provision tied to extended presence. These shorter thresholds can create source-country exposure earlier than under modern OECD-style treaties.
Article 7
Business Profits
Generally reserves business profits to the residence state unless a permanent establishment exists in the other state.
This article matters for U.S. firms operating in Egypt's energy, infrastructure, and services sectors. Article 5 PE analysis must be completed before reliance on Article 7 protection.
Article 10
Dividends
Provides treaty limits on source-country dividend withholding in qualifying cases.
The dividend article's 5 percent and 15 percent ceilings are the quick snapshot, but Egyptian domestic withholding interactions and the article's ownership thresholds control the practical outcome.
Article 11
Interest
Limits source-country withholding on qualifying interest.
The Egypt treaty does not eliminate interest withholding outright. The 15 percent ceiling reflects 1980-era drafting, and government and similar carve-outs may apply subject to article-level review.
Article 12
Royalties
Limits source-country withholding on qualifying royalties.
The royalty article applies a 15 percent ceiling, which is high relative to modern U.S. treaties. Category classification for software, patent, and copyright payments remains important.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- Egypt treaty documents pageVerified 2026-05-20
- Official U.S.-Egypt treaty PDFVerified 2026-05-20
- IRS Tax Treaty Table 1Verified 2026-05-20
- Treasury treaties in force listVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.