Version 3 | September 2023

The rejection of the Tax Ruling request- mandatory rejection ZATCA rejects Tax Ruling request in the following cases: 1. If the formal of the request is not submitted correctly in accordance with this guideline. 2. If the issue that requires Tax Ruling: 2.1. Include disputed tax amounts 2.2. Require an explanation of a foreign laws 2.3. Require an explanation of non-tax legislation 2.4. Apply to default deliveries or activities that the applicant did not or intend to undertake 2.5. If the request related to VAT and the issue is not related to the economic activity of the taxable person who requested the Tax Ruling or if the applicant is not a taxable person 3. If ZATCA has any concerns that the Tax Ruling may be used for purposes other than the intended explanation. 4. If the applicant is subject to inspection, auditing or investigation by ZATCA or if the applicant submit an objection or appeal that is currently being considered regarding issues related to the same type of tax subject of the Tax Ruling request. 5. If the taxpayer who requested the Tax Ruling is a party to a legal dispute related to the issue for which the taxpayer requested the Tax Ruling. 6. If the taxpayer asked ZATCA to express its opinion about issue, and ZATCA deems that the taxpayer will use this opinion to resolve a dispute among different parties (not include ZATCA). 7. If the Tax Ruling request failed to provide ZATCA with sufficient facts and information related to the issuance of Tax Ruling. It requires ZATCA to define the issue subject of the Tax Ruling request. 8. If the request is submitted by or behalf of taxpayer who provide misleading or incorrect information or statements on previous Tax Ruling request. 9. If a Tax Ruling has been issued regarding certain issue. But the person, who obtained the Tax Ruling, request an additional confirmation if the tax treatment stipulated in the Tax Ruling will be applied to the transaction after its restructured or amend agreements governed by. 10. If the request requires ZATCA to do the following 10.1. Imposition or abolition of penalty 10.2. Registration or deregistration of person 10.3. Validate any tax return or any information provided by this person 10.4. Bench trail of any person 10.5. Claim an outstanding debt to any person 10.6. Resolve or ‎decide in a dispute 10.7. Issue an opinion that can be used against ZATCA Note: If one of mandatory rejection reasons arises after submitting in progress Tax Ruling request, the applicant will be responsible for notifying ZATCA with the reason of mandatory rejection as soon as becoming aware of it. If the applicant did not notify ZATCA with the reason of mandatory rejection, the Tax Ruling issued by ZATCA will be cancelled. 5.7 The impact of the rejection of the Tax Ruling request ZATCA will inform the applicant of refusing the ruling request or refusing the issuance of the ruling. If ZATCA rejected the Tax Ruling as a result of failure to provide ZATCA with required information during the period of submitting the information, the same ruling request cannot be submitted without providing the additional information. 6. Processing of Tax Ruling request