KSA Transfer Pricing Regulations

To enable Kingdome tax authorities to adhere to the aforementioned convention, the General Authority of Zakat and Tax (GAZT) in the Kingdom of Saudi Arabia (KSA) issued a draft of Transfer Pricing Bylaws (TP Bylaws) for public consultation.
On 15 February 2019, the GAZT formally discharged the ultimate TP Bylaws. Besides the TP Bylaws, the GAZT moreover issued a set of Frequently Asked Questions (FAQs) and answers to those questions. As specified within the FAQs archive, the answers to FAQs don\’t represent GAZT\’s elucidation of the TP Bylaws, which the laws and regulations of TP Bylaws should prevail in case of any inconsistency.


  • The TP Bylaws are applicable on all Taxable Persons, as defined in the Income Tax Law. This includes entities that are jointly owned by GCC and foreign (non-GCC) shareholders.
  • Permanent establishments and branches of foreign companies are also subject to TP Bylaws.
  • Transactions between domestic related parties.
  • Companies that are owned 100% by GCC nationals, and are subject only to Zakat, are not subject to TP documentation requirements relating to Master File, Local File, and DFCT. Such entities are subject to requirements relating to the filing of Country-by-Country Report (CbCR), provided they meet the limit prerequisite for worldwide net incomes (being in excess of SAR 3.2 billion.

Transfer pricing documentation and timelines

Taxpayers entering into transactions with associates are required to:

  • To submit a controlled transactions disclosure form.
  • To submit an auditor certificate.
  • Maintain a master file and a local file containing prescribed documents and information;
  • Keep and maintain prescribed country-by-country report, where applicable;
  • Keep and maintain any other information and document in respect of transaction with its associate as may be prescribed; and keep the files, documents, information, and reports specified in clauses (a) to (c) for the period as may be prescribed.

These documents are required to be provided to the Authority in the course of any proceedings under this Bylaws, if so required, within 30 days or such extended time as allowed by Authority.[/et_pb_text][/et_pb_column][/et_pb_row][/et_pb_section]

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