On 15 February 2019, the Kingdom of Saudi Arabia (KSA) General Authority of Zakat and Tax (GAZT) released Transfer Pricing regulations. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. Transfer pricing refers to pricing arrangements in relation to all aspects of intra-group transactions occurring between related business entities. These include transfers of tangible goods, provision of services, transfers of intellectual property, issuance of loans, and other financing transactions.

The stakes are high:

The factors driving intensified scrutiny of transfer pricing arrangements are beyond the control of most companies, but the risks to your organization are very real. They include:

• Tax penalties under the tax reassessments and interest on overdue tax;
• Double taxation of income if relief under tax treaties is not available;
• Uncertainties regarding tax payments;
• Damage to reputation and corporate brand; and
• Conflicts with regulatory authorities can be expensive and time consuming to resolve.

How we can help you:

We help businesses to build, manage, document, review, and defend their transfer pricing policies and processes aligning them with their business strategy. Our transfer pricing experts work with you to build proactive, pragmatic, and integrated strategies that address the tax risks of today’s businesses and help your business achieve its potential.

• Development of strategy and policy
• Assistance to support transitions to new documentation requirements
• Governance optimization and decision-making process to help:
  • Coordinate across organization
  • Reduce the impact of year-end  adjustments
  • Monitor transfer pricing footprint
• Controversy risk assessment, remediation, or mitigation as a result of documentation requirements.

Transfer Pricing Services:

INSIGHT’S Transfer Pricing Services practice helps companies develop and implement economically supportable transfer prices, document outcomes, and respond to tax challenges.
We can help companies manage their transfer pricing issues through such services as:

Related Parties:

We will critically assess related parties under the Transfer Pricing Bylaws

Transfer Pricing Methods:

We will provide insightful advice on the appropriateness of the Transfer Pricing method used as per Bylaws for
determining the arm’s length value of controlled transactions

Impact Assessment:

The financial impact on the tax of the client will be assessed by using the appropriate Transfer Pricing method for
determining the arm’s length value of controlled transactions.

Policies and Procedures:

To determine the impact of Transfer Pricing Bylaws on the policies and processes of the organization