Home » ACCA event: Transfer Pricing by-laws in Saudi Arabia (Riyadh)

ACCA event: Transfer Pricing by-laws in Saudi Arabia (Riyadh)


We share the conference held on April the 17th, 2019 in Riyadh, on «Transfer pricing by-laws in Saudi Arabia», in which Mr. Enrique Díaz Tong was the principal speaker.

The event was organized by the prestigious organization ACCA (https://www.accame.me/), and took place in the main auditorium of the General Authority of Zakat and Tax – GAZT.


On 10 December 2018, Saudi Arabia’s General Authority of Zakat and Tax (GAZT) published draft transfer pricing by-laws (TP By-laws) for public consultation. The TP By-laws broadly follow international standards, including the arm’s-length principle and documentation standards as set out in the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines.

As per the GAZT website, “the TP By-laws are ‎applicable to persons considered taxpayers in Saudi Arabia under the corporate ‎Income Tax Law. Generally, this includes – without limitation – multinational enterprise ‎groups (MNE Groups), one or many members of which are deemed a taxable person in Saudi Arabia.”‎

The TP By-laws introduce new compliance requirements for fiscal years ending on or after 31 December 2018, including the submission of a Controlled Transaction Disclosure Form – due within 120 days from the end of the fiscal year end and filed as part of the annual income tax declaration. Additionally the TP By-laws introduce transfer pricing documentation and country-by-country (CbC) reporting requirements that are broadly aligned with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 Final Report.


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