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Saudi Arabia: Transfer pricing regulations finalized, accompanying FAQs released

Saudi Arabia: Transfer pricing regulations finalized

The General Authority of Zakat and Tax (GAZT) in the Kingdom of Saudi Arabia on 15 February 2019 released final transfer pricing regulations (or bylaws) as well as a set of “frequently asked questions” (FAQs).


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A draft version of the transfer pricing regulations was released for public consultation in December 2018.

Among the measures in the final version of the transfer pricing regulations are items concerning:

  • The effective date of the bylaws and rules for transfer pricing documentation (e.g., transfer pricing documentation requirements applicable for the reporting year ending 31 December 2018; GAZT may seek transfer pricing documentation for transactions undertaken during the years prior to 2018; taxpayers allowed 30 days for submitting the requested documentation to GAZT)
  • Disclosure form for controlled transactions (e.g., requiring detailed information about all controlled transactions)
  • Rules for determining related persons or parties and effective control
  • Applicability of the transfer pricing regulations on all taxable persons including Gulf Cooperation Council (GCC) entities, permanent establishments, and branches of foreign companies
  • Rules for transfer pricing documentation and timelines (generally in line with the requirements under the OECD base erosion and profit shifting (BEPS) Action 13 for country-by-country reporting, Master file, and Local file documentation)


Read a February 2019 report [PDF 209 KB] prepared by the KPMG member firm in Saudi Arabia

KPMG webinar

The KPMG member firm in Saudi Arabia is providing two webinar events concerning the final transfer pricing regulations on Monday, 25 February 2019.


Register for the first webinar and the second webinar

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