Background

A bank objected to the tax authority's assessment of its stamp taxes over a period from 09/11/1987 to 20/11/1989 and the dispute was referred to the committee of appeals. The committee decided to uphold the tax mission's assessments. The bank filed the case to appeal this decision.

The court upheld the committee's decision.

The bank appealed the ruling before the court of appeal. The court abandoned the appealed ruling and the committee's decision and ruled that the tax authority had no right to collect stamp taxes from the bank for this period.

Decision

The tax authority appealed the ruling before the court of appeal and stated in its grounds of appeal that the ruling had erred in the application of law because Article 57 of Egypt Law No. 111/1980 stipulated that a banking guarantee should be applicable to stamp taxes and such a guarantee should not be covered by cash.