The Egypt to UAE tax treaty that most guides still describe was signed on 12 April 1994 and no longer applies. Article 31(3) of the agreement signed in Abu Dhabi on 14 November 2019 terminates it. The current agreement was published in the Egyptian Official Gazette No. 22 of 3 June 2021 and is the text the Egyptian Tax Authority publishes as the bilateral agreement with the UAE.

That matters because the new agreement changed the residence definition, added a principal purpose test, and set different rates on dividends, interest and royalties. It matters more because the Egyptian side of the ledger moved again in July 2026: Laws 150 to 153 of 2026, published in Official Gazette No. 30 bis (a) of 28 July 2026, rewrote the real estate disposal tax, the capital gains rules on unlisted shares, the dividend withholding article and the stamp duty on Egyptian Exchange trades. This guide covers what the current treaty actually does for an Egyptian living in Dubai, and what Egypt still charges on Egyptian income and Egyptian assets regardless of where you live. The UAE half of the picture is in our guide to what a tax-free UAE salary really leaves you owing.

The Treaty in Force Is the 2019 One, Not the 1994 One

Article 31 of the current agreement provides that it enters into force on the date of the last notification of completed constitutional procedures, applies to withholding taxes on income derived on or after 1 January of the calendar year following entry into force, and to other income taxes for fiscal years beginning on or after that date. Article 31(3) then states that the agreement signed in Cairo on 1 Dhu al-Qi’dah 1414H, corresponding to 12 April 1994, ceases to have effect from the moment the new agreement takes effect under paragraph 2.

The Egyptian ratification chain is documented: the agreement was approved by Presidential Decision No. 558 of 2020 and published in the Official Gazette No. 22 of 3 June 2021. The UAE Ministry of Finance records entry into force on 19 April 2021, which on the Article 31(2) mechanism puts first application at 1 January 2022.

Anything you read that quotes a 1994 article number, a 1994 dividend rate, or the 1994 residence formula is describing an instrument that has been replaced. That includes a large amount of adviser marketing content still online.

Who Counts as a UAE Resident Under Article 4

Article 4(1) defines a resident of a contracting state as any person who, under the laws of that state, is subject to tax there by reason of domicile, residence, place of incorporation, place of management or any other criterion of a similar nature. The definition excludes anyone taxable in that state only on income from sources within it.

There is no nationality condition. That is the important structural difference from several other UAE treaties: the Kenya agreement and the Netherlands convention both limit UAE residence to UAE nationals, which locks expatriates out entirely, as our guide to the Kenyan treaty gap sets out. An Egyptian in Dubai is not excluded by their passport.

The difficulty is the phrase “subject to tax.” The UAE levies no personal income tax, so an individual’s claim to be subject to tax there by reason of residence is not self-evident from the words alone. The practical route is documentary: obtain a UAE tax residency certificate from the Federal Tax Authority under the domestic tax residence rules, and present that when a treaty position is claimed. Article 2(3)(b) of the agreement lists the UAE taxes covered as the income tax and the corporate tax, which is the textual anchor for treating UAE tax residence as engaging the agreement.

Where you are resident in both states, Article 4(2) runs the standard ladder: permanent home available to you, then closer personal and economic relations, then habitual abode, then nationality, then mutual agreement between the competent authorities.

The Source Rule That Catches Secondments

Article 3(b) of the Income Tax Law No. 91 of 2005, as replaced by Law No. 30 of 2023, treats as Egyptian-source “income borne by an employer resident in Egypt, even if the work is performed abroad.” The test is who bears the cost, not where the desk is.

Read that against the two common Dubai arrangements. If you resign in Cairo, sign with a UAE employer, and that employer bears your salary, Article 3(b) does not reach you. If you are seconded to a Gulf project while your Egyptian employer continues to bear the cost, or recharges only part of it, the salary is Egyptian-source income and Egyptian withholding follows it wherever you are standing.

Article 3(y), replaced by the same law, does the equivalent for rent, license fees and royalties: amounts borne by a person resident in Egypt, or borne by a permanent establishment in Egypt even where the owner of that establishment is non-resident, are Egyptian-source.

The 90-day service permanent establishment

Article 4 of the same law, also replaced by Law 30 of 2023, defines a permanent establishment on post-BEPS lines. Two thresholds matter for anyone running a UAE consultancy with Egyptian clients:

  • A building site, construction, installation or assembly project, or supervisory activities connected with it, is a permanent establishment where it continues in Egypt for periods totaling more than 90 days in any 12-month period.
  • The furnishing of services, including consultancy services, through employees or other engaged individuals is a permanent establishment where the service to the same project or a connected project continues in Egypt for periods totaling more than 90 days in any 12-month period.

The article also treats as dependent an agent who acts exclusively or almost exclusively for one or more closely related enterprises, and one who habitually plays the principal role in concluding contracts that are routinely concluded without material modification. A UAE free zone company billing Egyptian clients for on-site work should be counting days. The UAE side of that structure is covered in our guide to UAE corporate tax for freelancers and small businesses. Türkiye’s 1993 UAE agreement uses the same liable-to-tax wording, with a nationality step in the tie-breaker that points Turkish citizens home: see Turkish tax residency and the Türkiye to UAE treaty.

What Egypt Charges on Egyptian Assets, Whatever Your Residence

Four separate charges on Egyptian assets were rewritten in July 2026, and every one of them reaches a non-resident.

Charge Rate Deadline
Disposal of built property or land for building (Article 34) 2.5 percent of the gross disposal value, no reduction Payable within 60 days of the disposal
Gains on unlisted shares and company quotas (Article 46 bis 3) Chargeable whether the gain is realized in Egypt or abroad A non-resident disposer computes and remits within 60 days
Dividends from an Egyptian company (Article 56 bis) 10 percent, or 5 percent if the securities are listed on the Egyptian Exchange, with no cost deduction Withheld and remitted within five working days of the start of the following month
Stamp duty on Egyptian Exchange trades (Law 153 of 2026) 0.5 per thousand on the buyer and 0.5 per thousand on the seller, resident or non-resident; 0.25 per thousand each where the purchase and sale happen on the same day Withheld by the settlement entity within five days of the start of the following month

The 60-day clocks are the part that catches people. Both the property disposal tax and the unlisted-share gain are self-assessed obligations with a two-month fuse, and the delay charge in Article 110 of the Income Tax Law starts running the day after the period expires. Selling the family apartment in Heliopolis by power of attorney from Dubai starts that clock on the disposal date, not on the day the funds reach you, and moving the proceeds is a separate exercise covered in our guide to sending money from the UAE.

What counts as a disposal of property

Article 34 as replaced by Law No. 151 of 2026 is deliberately wide. The 2.5 percent applies whether the disposal covers the whole property, a part of it or a single residential unit, whether the buildings sit on land owned by the taxpayer or by someone else, and whether the contracts are registered or unregistered. It applies to an heir disposing of inherited property. Taxable disposals include sale, bequest, donation or gift to anyone other than ascendants, descendants or a spouse, the grant of a usufruct right, and a lease for more than 50 years.

The exclusions are narrow: forced sales whether administrative or judicial, expropriation for public benefit or improvement, and donations to the government, local administration units, public legal persons or public-benefit projects. Contributing the property as an in-kind share in the capital of a joint stock company is excluded provided the corresponding shares are not disposed of for five years.

One taxpayer-friendly element in the replacement text is worth knowing: the gross disposal value is determined by what is stated in the disposal contract, and the burden of proof falls on the Tax Authority where it disputes that value.

What the Treaty Caps, and Where It Gives an Individual Nothing

Income Treaty article Source-state ceiling
Dividends, corporate holder with at least 10 percent of capital for 365 days Article 10(2)(a) 5 percent of the gross
Dividends, all other cases including individuals Article 10(2)(b) 10 percent of the gross
Interest Article 11(2) 10 percent of the gross
Royalties Article 12(2) 10 percent of the gross
Gains on shares in a company resident in a state Article 13(5) Taxable in that state, no cap
Employment exercised in the UAE Article 15(1) Taxable only in the UAE
Pensions and annuities from past employment Article 18(1) Taxable only in the state of residence

Two lines deserve attention. The dividend cap of 10 percent for an individual is exactly the Egyptian domestic rate under Article 56 bis, so the treaty delivers nothing on an ordinary shareholding; the 5 percent tier is reserved for companies with a 10 percent stake held for 365 days. And Article 13(5) lets Egypt tax gains on shares or other rights representing a share in the capital of a company resident in Egypt without any ceiling, which sits directly on top of the unlisted-share charge in Article 46 bis 3.

Article 18(1) runs the other way and is the most valuable line in the agreement for an individual. Pensions, annuities and similar payments made in consideration of past employment to a resident of a contracting state are taxable only in that state. For an Egyptian pension paid to a treaty resident of the UAE, that removes the Egyptian charge, and the UAE taxes no personal income. This is the opposite of the source-state pension rule that catches UK pensions paid to UAE residents. Government service pensions stay under Article 19(2).

The anti-abuse article that is easy to overlook

Article 30 is a principal purpose test. A benefit under the agreement is denied for an item of income if, having regard to all relevant facts and circumstances, obtaining that benefit was one of the principal purposes of any arrangement or transaction, unless granting it in those circumstances accords with the object and purpose of the agreement. That is a modern provision the 1994 treaty did not contain, and it applies to individuals as well as to structures.

Article 22 preserves each state’s right to apply its own laws on income and profits from hydrocarbons, notwithstanding anything else in the agreement.

The Order to Do This In

  1. Establish who bears your salary. Article 3(b) turns on the employer bearing the cost, not on where you work, so a secondment structure is the first thing to check.
  2. Get a UAE tax residency certificate before you need to claim anything under the treaty, since the “subject to tax” wording in Article 4(1) is where a claim is most likely to be tested.
  3. Calendar the 60-day clocks for any Egyptian property disposal or unlisted-share sale, and note that the disposal date, not the settlement date, starts them.
  4. Count Egyptian project days if you consult into Egypt from the UAE. The threshold is more than 90 days in any 12-month period for both construction and services.
  5. Do not expect the treaty to reduce dividend withholding on a personal shareholding. Ten percent is both the treaty ceiling and the domestic rate.
  6. Check the pension position separately. Article 18(1) is a residence-state rule, and Article 19(2) carves out government service pensions.
  7. Stop citing 1994. If an adviser quotes an article number from the old agreement, they have not read the instrument that governs your position.

What We Could Not Verify

The Egyptian Tax Authority publishes the consolidated Income Tax Law No. 91 of 2005 only as a scanned image with no extractable text, so the residence test for individuals in Article 2 of that law could not be quoted verbatim here. The source rules, the permanent establishment definition and the 2026 charges described above come from the machine-readable texts of the amending laws, Law 30 of 2023 and Law 151 of 2026, published by the Authority. Confirm the residence article directly with the Egyptian Tax Authority before relying on a day count.

The date of entry into force of the 2019 agreement is recorded by the UAE Ministry of Finance as 19 April 2021, and that page could not be opened from here. What is verified directly from the Authority’s own text is the signature date of 14 November 2019, the Official Gazette publication of 3 June 2021, and the Article 31(3) provision terminating the 1994 agreement. If the exact first year of application matters to your filing, ask the competent authority rather than inferring it.

Egyptian personal income tax bands and the personal exemption have been changed repeatedly since 2023 and are deliberately not tabulated here, because the relevant charges for someone living and working in the UAE are the source rules and the asset charges rather than the salary bands.

Frequently Asked Questions

Is there a tax treaty between Egypt and the UAE?

Yes, and it is not the one most guides describe. The current agreement was signed in Abu Dhabi on 14 November 2019, approved by Presidential Decision No. 558 of 2020, and published in the Egyptian Official Gazette No. 22 of 3 June 2021. Article 31(3) terminates the agreement signed in Cairo on 12 April 1994.

Can an Egyptian in Dubai use the Egypt to UAE treaty?

There is no nationality condition in Article 4(1), unlike the Kenyan and Dutch agreements with the UAE, so an Egyptian passport does not exclude you. The test is whether you are subject to tax in the UAE by reason of domicile, residence, place of management or a similar criterion, which in practice means holding a UAE tax residency certificate from the Federal Tax Authority.

Does Egypt tax my Dubai salary?

Not where a UAE employer bears the cost. Article 3(b) of Law No. 91 of 2005, as replaced by Law No. 30 of 2023, treats income borne by an employer resident in Egypt as Egyptian-source even if the work is performed abroad, so a secondment where the Egyptian employer keeps bearing the salary is caught.

What tax do I pay if I sell property in Egypt while living in the UAE?

2.5 percent of the gross disposal value under Article 34 of the Income Tax Law as replaced by Law No. 151 of 2026, with no deduction and no reduction, payable within 60 days of the disposal. It applies to registered and unregistered contracts alike, to inherited property, and to gifts other than to ascendants, descendants or a spouse.

Is a long lease of Egyptian property taxable as a disposal?

A lease for more than 50 years is treated as a taxable disposal under Article 34, as is the grant of a usufruct right over the property.

What happens if I sell shares in an Egyptian company from abroad?

Article 46 bis 3, as replaced by Law No. 151 of 2026, charges gains on the disposal of unlisted shares or company quotas whether the gain is realized in Egypt or abroad, and requires a non-resident disposer to compute and remit the tax within 60 days. Treasury bill gains realized by a non-resident are outside the charge.

How much Egyptian tax is withheld on dividends paid to a non-resident?

10 percent with no cost deduction under Article 56 bis as replaced by Law No. 151 of 2026, reduced to 5 percent where the securities are listed on the Egyptian Exchange. Bonus share distributions are excluded. The treaty ceiling for an individual is also 10 percent, so it gives no additional relief.

Is there stamp duty on trading Egyptian shares from the UAE?

Yes. Law No. 153 of 2026 charges 0.5 per thousand on the buyer and 0.5 per thousand on the seller, resident or non-resident, on the gross value of sales of securities listed on the Egyptian Exchange, falling to 0.25 per thousand on each side where the purchase and sale occur on the same day. Licensed market makers are exempt.

Will my Egyptian pension be taxed if I live in the UAE?

Article 18(1) of the agreement provides that pensions, annuities and similar payments made in consideration of past employment to a resident of a contracting state are taxable only in that state, subject to Article 19(2) for government service pensions. For a treaty resident of the UAE that removes the Egyptian taxing right, and the UAE levies no personal income tax.

When does consulting into Egypt from Dubai create a permanent establishment?

Under Article 4 of the Income Tax Law as replaced by Law No. 30 of 2023, when services including consultancy services provided to the same project or a connected project continue in Egypt for periods totaling more than 90 days in any 12-month period. Construction, installation and assembly sites and their supervisory activities use the same 90-day threshold.

Does the treaty stop Egypt taxing gains on Egyptian shares?

No. Article 13(5) allows the state where the company is resident to tax gains from the disposal of shares or other rights representing a share in its capital, with no ceiling, and Article 13(4) does the same for shares in companies whose assets consist principally of immovable property in that state.

What is the principal purpose test in the treaty?

Article 30 denies a treaty benefit for an item of income if, considering all relevant facts and circumstances, obtaining that benefit was one of the principal purposes of an arrangement or transaction, unless granting it accords with the object and purpose of the agreement. The 1994 agreement contained no equivalent provision.

Official Sources

Information current as of September 2026. Egyptian tax law has been amended repeatedly in 2023, 2024, 2025 and 2026, the Arabic text of the agreement is the authoritative version, and residence is decided on the facts of your own case. Confirm your position with the Egyptian Tax Authority or an Egyptian tax adviser before relying on any treatment described here.