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Navigate ZATCA's regulatory landscape with precision. Ensure full alignment with the 2019 TP Bylaws and the latest Country-by-Country (CbC) reporting standards.
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Saudi Arabia implemented its Transfer Pricing Bylaws in 2019 to prevent profit shifting and ensure cross-border transactions follow the Arm's Length Principle. Governed by the Zakat, Tax and Customs Authority (ZATCA), these rules apply to all taxpayers subject to Tax or Zakat.
The 2026 enforcement cycle focuses heavily on the SAR 6 Million transaction threshold for Master/Local files and the mandatory Article 3 Notification for MNE groups.
The foundational framework requiring all related-party transactions to be at arm's length, applicable to both Tax and Zakat payers.
Mandatory Master File and Local File preparation for entities with controlled transactions exceeding SAR 6 Million per annum.
Submission of the Disclosure Form is required as part of the annual income tax or Zakat return, regardless of transaction value.
Global group overview and TP policies.
Required if transaction values exceed SAR 6 million. It must provide an overview of the MNE groups global business, including intangible property (IP) and financing arrangements.
ZATCA expects this to be ready by the tax return deadline and submitted within 30 days of a formal request.
Detailed KSA entity transaction analysis.
The Local File must include a detailed functional analysis (FAR) of the Saudi entity and specific economic analysis justifying the pricing of intercompany transactions.
Alignment with the Master File is critical to avoid discrepancies during a ZATCA audit.
Mandatory for groups over SAR 3.2 Billion.
MNE groups with consolidated revenue exceeding SAR 3.2 Billion must file a CbCR. Additionally, every KSA constituent entity must file an **Article 3 Notification** on the ZATCA portal within 120 days of the year-end.
Secondary filing rules apply if the Parent jurisdiction does not exchange reports with Saudi Arabia.
Preparation of fully compliant ZATCA documentation.
Representation and technical support during tax queries.
Economic analysis using Middle Eastern and Global databases.
Managing CbCR portal registrations and compliance filings.
ZATCA is intensifying audits on management fees and financial guarantees. Is your SAR 6M+ documentation audit-ready?
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