A comprehensive framework for transfer pricing is essential to ensure MNEs’ compliance with transfer pricing legislation and guidelines. The transfer pricing framework in Egypt at present is incomprehensive because of the lack of compendious transfer pricing guidelines and because the tax administration does not have sufficient resources and capacity. To amend this, it is necessary to issue comprehensive transfer pricing guidelines in a timely manner; to build the tax authorities' transfer pricing capacity; to extend the usage of information technology; and to introduce safe harbour measures in order to simplify transfer pricing provisions and minimize the compliance burden and costs.