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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