Transfer Pricing in the KSA
Transfer Pricing in the KSA
Event Date
TP Bylaws issued in KSA for Taxpayers and Mixed Entities February 2019
TP Guidelines issued March 2019
Proposal to extend TP Bylaws in KSA to Zakat Payers July 2022
TP Bylaws amended - Zakat Payers in scope & APA program created April 2023
New TP Bylaws applicable January 2024
Step 1: Identify Related Parties Step 2: Identify Controlled Step 3: Set Arm’s Length Pricing
Transactions
01 Functional Analysis and 02 Select Most 03 Economic Analysis 04 Select the Price
Value Chain Appropriate Method
Requirement Related Party Transaction Amount Phase 1 (FY 2024– Phase 2 (FY 2027
(Aggregate) FY 2027) onwards)
Local File and Less than SAR 48 million Not Applicable Not Applicable
Master File
Between SAR 48 million to SAR 100 Voluntary Required
million
More than SAR 100 million Required Required
CTDF and Affidavit Mandatory requirement irrespective of - -
threshold and phases
Notes:
1. The 1st phase include the all taxapayers subject to zakat collections, with exception of financing funds.
2. The 2nd phase include financing funds also.
3. Consolidated Zakat filers are exempt from TP compliance requirements.
4. Government-owned Zakat-exempt entities are exempt from local file and master file requirements.
5. Investment funds must comply from Phase 2.
TP COMPLIANCE BURDEN
Large & Highly Complex CBCR, Master File, Local File, Affidavit, CTDF
Yellow
(Moderate
Risk)
Red (High
Risk)