Version 3 | September 2023

Assumptions If ZATCA deems that the validity of Tax Ruling rely on assumptions related to future events or other issues, ZATCA will have the right to set assumptions that it deems appropriate and exclude the inappropriate ones. In such cases, ZATCA will stipulate these assumptions within the Tax Ruling and the content of the Tax Ruling will subject to them. In addition, ZATCA may deem that it is inappropriate to set assumptions. In such case, ZATCA rejects the Tax Ruling request or ask for more information from the applicant to be reviewed and analyzed. ZATCA prefers that the Tax Ruling request to be considered on basis of full facts and without assumptions, as ZATCA deems that it is in the interest of the applicant to submit full details for all relevant and important issues to ZATCA with aim to issue accurate and timely Tax Ruling. 7. Usage of Tax Ruling by ZATCA and taxpayers 7.1 Applicability of Tax Ruling When ZATCA responses for general or Private Tax Ruling, the purpose is to inform the applicant of how to apply current and in force tax laws at that time and according to facts that ZATCA pos­ sess and received. The content of a Tax Ruling may be affected by the following: Any changes to the applicant’s status or related facts Changes to tax laws and its implementing regulations in KSA Changes related to the interpretations of tax laws in KSA The applicant should not expect that the content of Tax Ruling or explanatory opinion will be valid in such cases or indefinitely. If the person is not sure that the interpretations included in the previous Tax Ruling still valid, he may choose to confirm this by requesting a new Tax Ruling. ZATCA is obliged by the tax treatments in the Tax Ruling and considers maximum accuracy when issuing a Tax Ruling, but any part of the Tax Ruling cannot be considered as an amendment to tax laws and its implementing regulations in KSA or any international agreements to which the Kingdom is a party (such as the Unified Agreement for VAT of the Cooperation Council for the Arab States of the Gulf). ZATCA provides the Tax Ruling according to facts that ZATCA possess and has submitted to by the applicant. If ZATCA finds that facts and information contained in the request do not reflect the truth or if there are essential facts or information related to the issue did not submit with the request to ZATCA and lead to change the tax treatment, in such case the Tax Ruling shall be null and unreliable. The Tax Ruling is special to the applicant and shall not share it with any other person. No other person shall not rely to this decision or apply it to his transactions.