Saudi Arabia: Amendments to transfer pricing bylaws
All Zakat payers will be required to disclose their related-party transactions in a transfer pricing disclosure form.
All Zakat payers will be required to disclose their related-party transactions.
The Board of Directors of the Zakat, Tax and Customs Authority (ZATCA) on 20 March 2023 approved amendments to the transfer pricing bylaws that will—effective for financial years (FYs) starting on or after 1 January 2024:
- Extend applicability of the transfer pricing bylaws to Zakat payers
- Introduce advance pricing agreement (APA) provisions for tax and Zakat payers
Compliance requirements
All Zakat payers will be required to disclose their related-party transactions in a transfer pricing disclosure form and submit an affidavit along with their Zakat declarations. They will also be required to prepare additional documentation (Master file and Local file (including benchmarking)) subject to the following thresholds:
Phase 1: Starting FY 2024 until FY 2026
Value of transactions with related parties |
Disclosure form and affidavit |
Additional documentation |
SAR 48 million and less |
Mandatory |
Not applicable |
Between SAR 48 million and SAR 100 million |
Mandatory |
Optional |
SAR 100 million and above |
Mandatory |
Mandatory |
Financing funds are excluded from Phase 1 but included in Phase 2.
Phase 2: FY 2027 onward
Value of transactions with related parties |
Disclosure form and affidavit |
Additional documentation |
SAR 48 million and less |
Mandatory |
Not applicable |
SAR 100 million and above |
Mandatory |
Mandatory |
For more information, contact the Global Leader of KPMG Global Transfer Pricing Services:
Komal Dhall | kdhall@kpmg.com
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