* IF the ownership in the non resident company is less than 10%, then it is excluded.
* If the revenues of the non resident company resulted from dividends, interest, royalties, management fees, or rents is less than 70%, then it is excluded.
* application is limited to resident entities.
*Revenues of the non resident entities are subject to tax or taxable at a rate exceeds 75% of Egypt's corporate tax rate (22.5%).