Transfer Pricing
Country Summary
Saudi Arabia

This document summarizes the transfer pricing requirements and regulations in Saudi Arabia. Saudi Arabia’s Transfer Pricing (TP) Bylaws align closely with the OECD TP Guidelines. While no significant surprises are found in these regulations, a few amendments were made following a public comment period. This summary covers the reference to international rules, the definition of related parties, transfer pricing documentation, and various aspects of TP practice in Saudi Arabia.


Transfer Pricing Rules in Saudi Arabia

Saudi Arabia’s Transfer Pricing Bylaws are substantially harmonized with the OECD guidelines. These bylaws have undergone some adjustments following a public comment period, although no major deviations from international standards are observed.

Definition of Related Party

In Saudi Arabia’s TP Bylaws, the definition of related parties encompasses a broad range of relationships, including natural persons, legal persons, and effective control. Effective control is defined as the ability to influence another entity’s business decisions directly or indirectly through various means, including management agreements, trust arrangements, equity control, and commercial connections.

Nature of Transfer Pricing Documentation

Saudi Arabia introduced Transfer Pricing Bylaws in February 2019, accompanied by the 2019 Transfer Pricing Guidelines. The latter offer guidance on implementing the Bylaws. A second edition of the guidelines was published in June 2020, maintaining consistency with the Bylaws.

Advance Pricing Agreement (APA)

Saudi Arabia has yet to implement rules regarding advance pricing agreements.

Audit Practice

Transfer pricing audit practices in Saudi Arabia are evolving, with an emphasis on entities in continuous loss positions and specific industries like energy, consumer goods, and technology.

Transfer Pricing Documentation

Under Article 18 of the TP Bylaws, ultimate or surrogate parent entities in Saudi Arabia must submit Country-by-Country (CbC) reports. TP Bylaws require every taxpayer with related-party transactions exceeding SAR 6 million to maintain a Master File and Local File.

Financial Statements

Banks and insurance companies in Saudi Arabia with shares listed on the Saudi Stock Exchange must publish financial statements following IFRS. Other listed and unlisted companies should adhere to accounting standards issued by the Saudi Organization for Certified Public Accountants (SOCPA).

Production Process for TP Relevant Returns, Documents, Forms, and Financials

TP documentation is encouraged to be maintained and submitted in Arabic. English or other languages may be accepted, but compliance with language requirements is essential.

Notification Requirement

Taxpayers are obliged to submit TP documentation within 30 days, with extensions possible.

Record Keeping

Taxpayers must retain TP documentation for five years, in accordance with the statute of limitations.

Penalties and Interest Charges

Tax evasion, including knowingly hiding information, leads to a 25% penalty on excess tax charged.

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