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Para. 3.4.10Status unknownSaudi ArabiaRegulation
Issued by Zakat, Tax and Customs Authority (ZATCA)
Application of Transfer pricing Guidelines
According to Article 22 of the regulation, the transactions conducted with related parties of the
Zakat payer are subject to the Transfer pricing guidelines issued by the Board of Directors of the
Authority under Resolution No. (6-1-19) dated 25/5/1440 AH, and any amendments thereto. The
aforementioned ministerial resolution included the coverage of Transfer pricing provisions for
Zakat payers starting on or after 01/01/2024 AD. The decision also included the application of
Transfer pricing provisions to Zakat payers in two phases:
Phase One: Zakat payers are required to submit the specified Transfer pricing documentation
(master file - local file) if the transactions with related parties reach 100 million Saudi Riyals or
more. Investment funds are exempted from the application of Transfer pricing provisions in this
phase.
Phase Two: This phase will start three years after the application of Phase One. In this phase,
Zakat payers are required to submit the specified Transfer pricing documentation (master file -
local file) if the transactions with related parties exceed 48 million Saudi Riyals. This phase also
includes investment funds.
In general, the purpose of Transfer pricing information is to ensure that the terms and conditions of
transactions between related parties are comparable to the terms and conditions of transactions
between independent parties. This requires the submission of a disclosure form along with the
Zakat payer's declaration to disclose transactions with related parties and the pricing methods
used for those transactions.
The Master File for Transfer pricing purposes refers to a file that contains guidelines about the
business and international activities of the multinational group to which the Zakat payer belongs,
in addition to the group’s transfer pricing policy and the economic functions and characteristics of
the related parties.
The Local File for Transfer pricing purposes refers to a file that contains detailed information
about the transactions that took place between the Zakat payer and the related parties.
Zakat payers and Zakat Activities
Introduction
Section 3 of Chapter One of the regulation includes provisions related to Zakat payers. The
sub-sections of this chapter include provisions regarding those subject to the regulation,
exemptions, and related provisions such as the determination and controls of residency.
Section 1 of Chapter Two includes a number of important provisions related to activities, such
as the commencement of Zakat collection, cessation of activity, mergers between Zakat
payers, and the consolidation of accounts. This guide reviews the most prominent provisions
related to zakat payers and activities.
Those subject to the provisions of the Regulation.
The Arabic text is the legally binding version. The English translation is provided for guidance only.
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