The Mergers & Acquisitions Review: Egypt

Overview of M&A activity

Due to the universal crisis resulting from the coronavirus pandemic, the performance of international and local markets has been dragged down, which has affected Egypt. However, the impact at the local Egyptian level has been less severe than in other countries with similar circumstances.

Egypt was the top regional target market for inbound M&A during the first quarter of 2020, with deals valued at US$2.4 billion. The first half of 2020 also saw Egypt emerge as the third-largest target nation for domestic M&A in the Middle East and North Africa region in terms of value, with Egypt's share of regional transactions rising to 8 per cent from 1 per cent during the same period in 2019.2

M&A deal value grew due to increased interest by investors in the healthcare, pharmaceutical, energy, mining, education and utilities sectors. Egypt also saw one of the region's two sole equity capital markets issuances, when Emerald Real Estate Investment raised US$13.1 million.3 Landmark M&A transactions in 2018 included Mubadala's US$935 million and Rosneft's US$1 billion acquisition of parts of the Zohr oilfield from Eni, Dr Oetker's acquisition of Tag El Melouk and SOCO International's acquisition of Merlon Petroleum El Fayum Company.

For the past two years, the Egyptian market and international investors have been monitoring the progress of the implementation of the government's economic and social development plan in light of the US$12 billion Egypt–International Monetary Fund (IMF) loan agreement, which was associated with a number of important measures including changes in the deposit and lending interest rate announced by the Central Bank of Egypt (CBE) and, most importantly, the removal of all FX controls and the free flotation of the Egyptian pound, which was followed by a severe currency devaluation. The severe devaluation of the pound saw Egyptian assets and securities lose more than 50 per cent of their value and, in conjunction with the positive performance of the government insofar as the IMF loan programme is concerned, as publicly noted by the IMF, had a major positive impact on M&A activity in Egypt. With the completion of the IMF loan, there are macroeconomic signals that Egypt has overcome all odds and begun its journey towards a stable economy, especially with regard to financial and monetary policies.

The CBE has modernised its monetary policy framework, focusing on inflation under a flexible exchange rate regime. The CBE intended to put in place a formal inflation target of 9 per cent and set interest rates according to the global economic conditions, and at the same time taking into consideration the recent rates of inflation.4

Overall, in 2019, Egypt's M&A deal value was announced as accounting for 75.1 per cent of the North African M&A deal value and 58.3 per cent of its volume, up from 48.4 per cent and 39.5 per cent, respectively, in 2018. General M&A in Egypt remained robust in 2019, with 14 deals worth US$1.3 billion compared with 15 deals worth US$1.9 billion in 2018, despite the global slowdown in dealmaking.5 Private equity, investment managers and financial institutions became more active in terms of the number of deals and their value. M&A transactions were closed in several sectors, including:

  1. media;
  2. education;
  3. oil and gas downstream;
  4. petrochemicals;
  5. telecommunications;
  6. renewable and traditional energy;
  7. manufacturing;
  8. food processing;
  9. education;
  10. fintech; and
  11. healthcare.6

In 2020, trans-border M&A were forecast to reach US$2.93 billion and increase to US$3.14 billion.7 However, this was not the case due to the global covid-19 crisis.

Introduction

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General introduction to the legal framework for M&A

The Egyptian legal system is a civil law system, which is influenced mainly by Islamic shariah and the French Civil Code. Hence, it is based on written legislation, rather than depending on judicial precedents as in common law countries. That said, the Egyptian Civil Code8 plays a prominent role in the legal framework since it governs and regulates all the general principles pertaining to contract law, including but not limited to all types of sale and purchase transactions. In other words, in the case of M&A transactions governed by Egyptian law, the Civil Code is one of the main pillars regulating such transactions.

In addition to the general rules stipulated under the Civil Code, M&A transactions are regulated in Egypt by diverse specific legislation depending on whether a transaction is public or private.

Key rules pertaining to M&A can be particularly found under the Egyptian Companies Law9 and its Executive Regulations, as amended, the Capital Market Law10 and its Executive Regulations, as amended, and the Egyptian Exchange Listing Rules, as amended.11

Furthermore, decisions and decrees issued by the following concerned key regulatory authorities constitute an integral part of the regulatory framework: the Egyptian Stock Exchange (EGX), the Financial Regulatory Authority (FRA) and the General Authority for Investment and Free Zones (GAFI).

Subject to the specific activity of a target company, other regulatory bodies might be involved, such as the CBE and various key ministries.

As a general rule, acquisitions involving transfer of title of shares of joint-stock companies and quotas of limited liability companies are the most common acquisition structures in Egypt. The transfer of unlisted shares is conducted over the counter (OTC) through an accredited broker registered with the EGX and appointed for such purpose. OTC transactions are not subject to the same level of regulation as public transactions. Any transaction exceeding E£20 million must be, inter alia, pre-approved by the EGX Pricing Committee, which convenes on a weekly basis to study and resolve on each envisaged transaction, and the FRA.

Strategies to increase transparency and predictability

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Developments in corporate and takeover law and their impact

Egypt has witnessed several legislative reforms that affect the M&A market, whether directly or indirectly.

In 2020, a new banking law was issued in addition to the data protection law, which has an indirect impact on M&A by encouraging foreign investors to invest in a similar business environment.

Additionally, 2018 witnessed several legislative amendments that have impacted the M&A market, including an increase of the mandatory tender offer trigger in the shareholding of a public company from 2 per cent to 5 per cent. Further, the FRA introduced numerous specific regulations regarding the acquisition of notable stakes in financial services companies.

The legislative amendments that have impacted the M&A market include an amendment of the Companies Law in relation to shareholders' agreements and preferred shares.

i Shareholders' agreements

Legal provisions exist to govern the concept of the shareholders' agreement. Shareholders' agreements are typically concluded between the founders and shareholders of a company so as to organise the relationship between the partners that are not contained in the articles of association that is ratified by GAFI on a designated form. Although there is no legal requirement to conclude agreements between sellers, buyers and target companies for share acquisitions, it is, however, customary in large acquisitions that parties conclude transaction agreements such as share purchase agreements and shareholders' agreements, as long as such shareholders' agreements do not include any contractual restrictions on the free tradability of the listed shares, since otherwise the same would be null and void.

Egyptian law does not explicitly regulate or recognise the concept of the drag-along right. There are no publicly available Court of Cassation judgments addressing the validity or enforceability of drag-along or similar rights. In addition, in practice, GAFI does not accept the inclusion of drag-along right provisions in a company's articles of association. Accordingly, drag-along right provisions fall under the scope of application of the general provisions of the Civil Code and the Executive Regulations of the Companies Law, and qualify as a conditional contractual obligation. Hence, the drag-along right is valid under Egyptian law since the fundamental conditions that trigger the drag-along right (i.e., a third-party bone fide purchaser wishing to acquire a majority or all of the capital of a target) do not conflict with the Civil Code. However, its enforceability remains untested.

Note that the same is applicable to put option provisions. Accordingly, put option provisions fall under the scope of application of the general provisions of the Civil Code and the Executive Regulations of the Companies Law and arguably qualify as a promise to contract.

In light of the foregoing, the introduction of a regulated shareholders' agreement will give parties to M&A transactions further comfort, since rights such as drag-along rights and put option rights will be incorporated into such shareholders' agreement.

ii Preferred shares

In the past, a company was not allowed to issue preferred shares unless its by-laws contained a provision allowing this at incorporation. In this respect, the new amendments to the Companies Law allow companies to issue preferred shares, even if such was not provided for in their by-laws at incorporation, so long as an extraordinary general assembly of such company vote representing three-quarters of the company's capital is obtained. At the outset, preferred shares were assumed to be incorporated with no limitations. However, shortly after the issuance of the new amendment of the Companies Law, GAFI issued a circular to limit the voting powers of holders of preferred shares to be capped at two-to-one. Preferred shares are advantageous for parties that wish to enjoy more voting and financial rights and contribute with the same capital, as opposed to ordinary shareholders.

Us antitrust enforcement: the year in review

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Foreign involvement in M&A transactions

Investing in Egypt was subject to a period of instability following the 2011 and 2013 revolutions. Although the devaluation of the Egyptian pound against the United States dollar in 2016 should have increased foreign investment into the country, political instability throughout the Middle East and North Africa have had a greater negative influence. Another problem that slowed down foreign direct investment was the high level of bureaucracy. However, several steps have been taken to enhance public service delivery and the domestic investment environment, and to re-attract significant foreign direct investment inflows.12

Egypt's foreign direct investment increased by US$970.5 million in the first quarter of 2020.13

Egypt was one of the African countries that received some of the largest amounts of foreign direct investment inflows in 2018. According to the CBE, foreign direct investment inflows increased to US$10.2 billion, while outflows stood at US$4.2 billion, which led to an increase of net foreign direct investment inflows of US$6 billion between July 2017 and March 2018. In parallel, total foreign investment reached US$14.9 billion due to portfolio investments. Further, the discovery of the largest gas reserves in the Mediterranean Sea, first in the country's western desert and then in the Zohr offshore field, has positively affected inflows into Egypt. As a result, Egypt saw around 1.6 per cent growth in inflows in relation to the oil industry in less than a year.

Foreign investments mainly come from countries with which Egypt has signed a bilateral treaty, including EU and Arab countries, and the United States. Notwithstanding this, the United Kingdom remains by far the largest investor in Egypt. Such direct investments mainly target the oil sector, followed by the construction, manufacturing, real estate and financial services sectors.

The countries that have been key players in M&A deals in Egypt include the United Arab Emirates (UAE), which currently enjoys very strong diplomatic and economic ties with Egypt; a large number of UAE public and private companies have been consolidating their presence in the Egyptian market via M&A.

Egypt is a party to more than 100 bilateral investment agreements with, inter alia, the majority of the European Union Member States, the United States, and some African, Middle Eastern and Asian countries. In addition, Egypt signed an agreement with the Mercosur bloc of Latin American nations in 2010.

Significant transactions, key trends and hot industries

Regional, international and local private equity and financial institutions are empowering the Egyptian economy. The renewable energy sector, and consumer-focused sectors such as food and drink, healthcare and education, have been the most active sectors. 2020 has witnessed the following transactions.

  1. A joint venture to build a private university in West Cairo between Palm Hills Development and Taaleem Management Services.
  2. Acquisition of Sahara Petroleum Company SAE for approximately US$50 million by National Energy Services Reunited Corp.
  3. Acquisition by the private equity fund Ezdehar Management of a minority stake in Al-Tayseer Healthcare Group through Ezdehar Egypt Mid-Cap Fund.
  4. Acquisition of diagnostics network Metamed by Gulf Capital. The buyers were a consortium of parties led by Mediterrania Capital Partners.
  5. Acquisition by Tana Capital, an Africa-focused investment company, of a minority stake in Alexandria Medical Investment Company, the majority shareholder of Mabaret Al Asafra Hospitals Group in Alexandria. The instruction included due diligence and drafting the transaction documents (share purchase agreement, shareholders' agreement and escrow). The transaction value was US$18 million and the deal closed in May 2020.
  6. Acino, a Swiss pharmaceutical company, acquired selected prescription and OTC products from Takeda pharmaceuticals for a total value in excess of US$200 million.

The past year witnessed the acquisition by Mubadala Petroleum of a 10 per cent stake in the Shorouk concession in Egypt's Zohr gas field for US$934 million as well as SOCO International's acquisition of Merlon Petroleum El Fayum Company.

Further notable transactions include:

  1. EFG Hermes' acquisition of a Cairo-based elementary schools' portfolio from Talaat Moustafa Group Holding, Egypt's largest listed real estate developer, for E£1 billion;
  2. Tag El Melouk, a market leader in the production of baking powder, vanilla and salt, among other products, selling 100 per cent of its shares to Dr Oetker; and
  3. Solvay Alexandria Sodium Carbonate (CCI) selling 100 per cent of its shares in a US$15 million buyout by state-owned companies Egyptian Ethylene and Derivatives Company, Sidi Kerir Petrochemicals Company and the Egyptian petrochemicals holding company ECHEM.14

Although in May 2019 Bank Audi announced its acquisition of the National Bank of Greece (NBG) in Egypt, it walked away from this transaction during the first quarter of 2020 due to the eruption of the Lebanese banking crisis, prompting it to sell the entirety of its operations in Egypt. NBG's plan to exit from the Egyptian market is in accordance with a wider plan to reduce its overseas presence.

While 2019 was intended to be more focused on initial public offerings by the government, the year witnessed some notable transactions, including:

  1. the joint venture of the fertiliser and ammonia arm of OCI (comprising Egyptian Fertilizers Company, Egyptian Basic Industries Corporation and ADNOC, a leading state-owned company operating in the fertiliser industry in the UAE), with a value of approximately US$5 billion;
  2. the sale of a majority stake in Taaleem Group, the owner and operator of Nahda University in Beni Suef, to CI Capital Holding for Financial Investments for a value of E£1.2 billion; and
  3. Cleopatra Hospital Group has also acquired the real estate assets of El Katib Hospital, and is currently finalising the business transfer agreement. El Katib Hospital is expected to add around 100 beds to its existing capacity and introduce a new urology centre of excellence.

New challenges have been seen due to a more difficult external environment, given the constricted global financial conditions. Egypt has successfully weathered recent capital outflows. Nevertheless, further strengthening of the policy buffers, including by containing inflation, enhancing the exchange rate's flexibility and reducing public debt, will be essential.15

According to CBE monthly inflation developments, 'nationwide annual inflation declined to 12.5 per cent in April 2019 as rural annual inflation declined to 11.9 per cent, from 13.8 per cent and 13.4 per cent, in March 2019, respectively'.16

According to the IMF review, the continued reinforcement of tourism and construction, and the rising production of natural gas are expected to increase GDP growth to 6 per cent due to the ongoing implementation of structural reforms, and should translate into stronger private investment. Inflation is expected to reach single digits in 2020. The current account deficit is projected to gradually narrow from 2.4 per cent of GDP in 2017 and 2018 to under 2 per cent of GDP in the medium term, and general government gross debt is expected to continue to decline to 74 per cent of GDP by 2022 or 2023.17

In parallel, the significant investment liberation measures that are currently being undertaken by the government – by way of example, the introduction of a new law for the setting up of a natural gas regulatory authority charged with licensing – aim to open up the gas market to competition.

Furthermore, the issuance of the New Industrial Law18 has made the establishment of manufacturing facilities easier through the introduction of a one-stop shop mechanism as an addition to the current practice of GAFI, under which the same concept is applied to establishing companies. These have encouraged local investors to establish companies or manufacturing facilities, or to expand their existing facilities, without being concerned about regularising the status of such facilities.

The free float of the Egyptian pound has affected inbound foreign investments through the contributions of non-residents purchases of real estate, and the net purchase by non-residents of companies and assets. Although purchases by non-residents have increased foreign direct investment into real estate, the real estate sector is still mainly being affected because of the increase in price of all the raw materials involved, which has affected costs and purchase prices, leading to stagnation.

Financing of m&a: main sources and developments

M&A are typically financed through equity or third-party financing, which includes credit financing, or a combination of equity and financing. Buyers tend to provide sellers with a warranty or documentary evidence, or both, confirming the availability of the acquisition financing. Typically, the payment of the purchase price is a condition precedent to a transfer of shares. Hence, if finance is not available, a transaction will never be closed.

There are no typical seller's assistance obligations. However, there are some regulatory restrictions under Egyptian law that could impact the financing structure, including the CBE regulatory instituted limitations and regulatory framework regulating acquisition financing; and financial assistance rules that under Egyptian law restrict a company from lending or guaranteeing the obligations of any of its board members.

Furthermore, in the case of a mandatory tender offer, a proposal submitted to the FRA must include a confirmation from a licensed bank in Egypt evidencing the availability of the financial resources to fund and cover an offer. Accordingly, short of a financial solvency confirmation, the FRA should not accept an offer proposal.

Subject to the parties' commercial agreement, financing may be structured as a condition (among other conditions) in asset-based transactions, where the transaction documents may reflect procurement of financing as a condition as supported by guarantees, warranties and the provision of evidence confirming the availability of financing.

It is, however, not customary to enshrine a seller's obligations to assist in relation to a buyer's financing in the transaction documents.

Private equity, investment managers and financial institutions have recently become more active in terms of the number of deals and their value.

Employment law

The relationship between employers and employees is governed by the Egyptian Labour Law19 and decrees of the Ministry of Manpower. Generally, the Employment Law favours and protects employees as supported by several court precedents issued in favour of employees. Although Egyptian law does not oblige employers to obtain approval of or consult employees during an acquisition process, the law has still restricted an employer's ability to make changes to the workforce during this process. In an acquisition, employees' rights (including their acquired rights) remain protected and may not be discretionally limited or changed by the employer. Employees' dismissals take place by virtue of court orders and are limited to specific major events. Further, any redundancies during acquisitions must take place in coordination with the Ministry of Manpower and subject to its approval.

The Labour Law obliges buyers to have all the employees of the seller remain with the target company or transfer to the buyer in the case of an asset deal. The application of such transfer varies whether an acquisition is for assets or shares. In a share transfer, employees do not transfer, since they remain with the target company; hence, an acquisition of shares does not involve an employee transfer process.

In an asset sale, pursuant to the Labour Law, in the event an establishment is transferred from one employer to another, employees of the transferred establishment are transferred automatically to the new employer. Both the former and new employers will be jointly liable for the fulfilment of their entire obligations as set out under the employees' employment contracts. Article 9, Paragraph 2 of the Labour Law states the following:

merging the establishment with another or transferring it by inheritance, bequeath, donation, or sale – even by public auction – or by assigning or leasing it or other such disposing actions shall not terminate the employment contracts of the existing employees. The successor employer shall be responsible jointly with the former employers for implementing all obligations arising from these contracts.

Based on Article 9, the Labour Law neither defines an asset sale nor sets out parameters to include a sale of business, whether in whole or partial. Hence, some sellers tend not to apply the conservative approach and have employees transferred. Although the Labour Law recognises the concept of employees' automatic transfer in the event of an asset sale, practically, the transfer of employees cannot automatically be implemented before the Social Insurance Authority due to bureaucracy.

That said, note that in the transfer of assets constituting a business, employees' and tax-related liabilities will remain shared, from a statutory standpoint, by both the purchaser and the seller. A new labour law has been discussed in Parliament since 2017, and the draft of that law has kept a provision to the same effect. Other provisions that are irrelevant to M&A have been either amended or introduced to grant employees more benefits (e.g., four months of maternity leave instead of three months20).21

Tax law

Taxation in Egypt is governed by a number of pieces of legislation mainly comprising the Income Tax Law22 and the Value Added Tax Law.23

Recently, capital gains realised from the sale of listed Egyptian shares by both resident and non-resident shareholders have been taxable at a rate of 10 per cent.24 For listed securities, the application of this tax was suspended for two years from 17 May 2015. This suspension was extended for an additional period of three years to 16 May 2020, and has been further extended until 31 December 2021.25

On the other hand, the sale of unlisted Egyptian shares by both resident and non-resident shareholders is subject to capital gains tax at a rate of 22.5 per cent on the gain realised.

Another applicable tax on sales of securities, whether listed or unlisted, is the newly introduced amendment to the Stamp Duty Tax Law whereby the purchase and sale of shares representing less than 33 per cent of a company's issued capital (during a consecutive period of two years) was reduced for non-residents to 1.25 per thousand from 1.5 per thousand, and reduced for residents to 0.5 per thousand from 1.5 per thousand. Such provision shall not apply to residents after the lapse of the extension pertaining to the capital gains tax applicable on listed shares. As per the Stamp Duty Law,26 stamp duty should be borne equally by the seller and the buyer. If the transferred shares represent 33 per cent or more of a company's issued share capital (as bulk in one transaction), the buyer shall pay stamp duty at a rate of 0.3 per cent and the seller shall also pay 0.3 per cent.

Further, although value added tax may seem irrelevant to M&A activities, its application is crystallised in the acquisition of assets – in the context of asset deals rather than stock deals – since a sale of assets is subject to value added tax at different rates according to the sold assets.

Article 107 of the Income Tax Law stipulates that if the Tax Authority finds that the rights of the public treasury are liable to be lost, the President of the Authority may request the competent summary matters judge to issue a warrant on petition for levying an attachment on the funds or assets deemed adequate for collecting rights that may be lost, whatever the holders of such funds.

Additionally, as per Article 1139 of the Civil Code, sums due to the state treasury for taxes, duties and any other dues are privileged in accordance with the conditions laid down by the laws and regulations issued in this connection. These sums shall be paid out of the proceeds of the sale of a property charged with this privilege, in whosoever's hand they may be, and before all other rights, whether privileged by a lien or secured by a mortgage, except the costs of legal proceedings.

By virtue of the above, the Tax Authority has the right to trace the assets of a target in whosoever's hands they may be to satisfy any sums due on the target to the state treasury, even if those assets have been transferred to, and are now owned by, the target. Although the privileged right of the Tax Authority is deemed to be a general privileged right that shall not entail, as a rule, tracing rights, this specific privileged right of the Tax Authority exceptionally entails the latter's right to trace the assets of the target, in whosoever's hands they may be, as indicated in the above-mentioned provisions.

Further to the above, note that the Tax Authority may have another legal basis for claiming the amount of taxes due on any target from any purchaser jointly with the target if a transfer of assets is considered to be a transfer of the target's business.27

Competition law

In 2018, the Egyptian Competition Authority (ECA) began adopting a new approach in its interpretation of the Competition Protection Law and its Executive Regulations, which has materially impacted M&A transactions. The ECA, via its novel interpretation of the law, deems that M&A transactions between dominant companies (defined as companies that control over 25 per cent of a specific market) must obtain the prior approval of the ECA prior to concluding a transaction, even if the transaction is concluded offshore. On the legislative front, the ECA is trying to introduce an amendment to the Competition Protection Law in Parliament to give it greater power in controlling mergers, and explicitly legalising this new approach and interpretation.

In that context, the ECA regards the potential merger between Uber and Careem (two of the biggest ride-hailing app transportation companies) to be a horizontal agreement, which as such violates Article 6(a) and (d) of the Competition Law.28 In this regard, the ECA issued decision No. 26 of 2018 on 23 October 2018. This decision obliges the two companies and their related parties, including the companies participating in their shareholding, to obtain the ECA's pre-approval prior to concluding any agreement related to the merger, establishing joint ventures or the purchase or sale of shares or assets of either company, either directly or indirectly.

Based on the above, if the buyer is a competitor of the seller, whereby both will have a significant share covering almost the whole market, the prior approval of the transaction by the ECA will be required. Otherwise, failure to procure approval will be subject to the penalty stipulated in Article 22 of the Competition Law: each party to the horizontal agreement shall be punished by a fine ranging between 2 per cent and 12 per cent of the total revenue of said party that was generated from trading the product or products that are the subject of the horizontal agreement during the violation period. In the event the competent court is unable to determine the aforementioned revenue, each party shall be punished by a fine amounting to no less than E£500,000 and no more than E£500 million. Such fines will be doubled in the case of recurrence.

The Cabinet and the President have recently approved draft amendments to the Competition Law, including a provision by virtue of which the penalty for failure to serve post-closing notifications upon acquiring, inter alia, assets, usufruct rights, shares or the joint management of two or more parties in the event that the combined annual turnover of the concerned parties in Egypt exceeds E£100 million according to their latest financial statements, will be calculated on a daily basis and until the required notification is made. However, such amendments have not yet entered into force.

Outlook

It is difficult to assess or provide an outlook for 2020 given the rapid changes due to covid-19. Forty per cent of healthcare executives said their companies are likely to acquire, partner or collaborate across healthcare sectors in 2020, citing access to technology as a reason their companies would pursue a deal. Considering that Egypt achieved an economic GDP growth rate of 5.5 per cent in the second half of 2018 (the highest growth in the Middle East according to the IMF), implemented the vast majority of the medium-term reform plan agreed upon with the IMF, stabilised the Egyptian pound foreign exchange rate, secured the relative availability of foreign currency within banking channels and realised a notable increase in the FX reserves at the CBE, a large number of analysers and practitioners remain optimistic as far as foreign direct investment and M&A activity are concerned.

In an attempt to reduce Egypt's increasingly large foreign currency debt (which is close to US$100 billion), a wave of privatisations of public sector assets, including power stations, financial institutions and infrastructure, is expected, whether in the form of direct sales or flotations on the stock exchange.

It is also envisaged that further reforms in connection with the regulatory framework for antitrust will take place, and it is expected that these will strengthen the role of the regulator. The sectors that will see the vast majority of M&A transactions in the coming 12 months include:

  1. renewable energy;
  2. oil and gas;
  3. petrochemicals;
  4. education;
  5. food processing;
  6. financial services;
  7. telecommunications;
  8. real estate; and
  9. sectors that will be impacted by Egypt's demographic power and potential (with the country's population standing at just over 100 million).

All of the above evidences Egypt's commitment to a strong investment environment.29

Footnotes

1 Omar S Bassiouny is a partner and Maha El-Meihy is a senior associate at Matouk Bassiouny & Hennawy.

3 ibid.

8 No. 131 of 1948.

9 No. 159 of 1981.

10 No. 95 of 1992.

11 The Board of Directors of the Financial Regulatory Authority Decree No. 11 of 2014.

15 IMF, 'Arab Republic of Egypt: Fourth Review Under the Extended Arrangement Under the Extended Fund Facility–Press Release; Staff Report; and Statement by the Executive Director for the Arab Republic of Egypt'.

17 See footnote 15.

18 No. 15 of 2017.

19 No. 12 of 2003.

20 Article 91 of the Labour Law.

22 No. 91 of 2005.

23 No. 67 of 2016.

24 Article 46 bis 5 of the Income Tax Law.

25 Law No. 199 of 2020.

26 No. 111 of 1980.

27 Article 80(3) of the Income Tax Law.

28 Law No. 3 of 2005.

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