Pillar Two in the GCC: Why Saudi Arabia Hasn’t Adopted a Domestic Minimum Top-Up Tax

September 4, 2026  ·  Tax Topics

Tax Intelligence International Tax Every other major economy in the Gulf has now legislated a domestic minimum top-up tax. Saudi Arabia has not. For a multinational group weighing where to headquarter its GCC operations, that single gap is becoming one of the more consequential regional tax differences to understand — not because it’s a loophole, […]

How the OECD Global Minimum Tax Still Affects Multinationals in Saudi Arabia

 ·  Tax Topics

Tax Intelligence International Tax A multinational group with Saudi operations doesn’t get to opt out of Pillar Two’s reporting and compliance machinery just because Saudi Arabia hasn’t enacted a domestic top-up tax. The GloBE rules operate at the group level, and the compliance clock has already started for large groups with a December year-end. Here’s […]

ZATCA’s Penalty Waiver Initiative Extended to December 2026: Who Qualifies

September 3, 2026  ·  Tax Topics

Tax Intelligence Tax Compliance ZATCA has now extended its fines-waiver initiative twice in 2026 — first through 30 June, then again through 31 December 2026. If your business has unpaid tax penalties sitting on the books from a late VAT return, a missed registration deadline, or a delayed CIT payment, this initiative is the cheapest […]

Saudi Special Economic Zones: Tax Incentives and the New Economic Substance Rules

 ·  Tax Topics

Tax Intelligence Special Economic Zones A 5% corporate income tax rate for twenty years is a rare enough offer that it changes where a multinational decides to book its Saudi operations. Saudi Arabia’s special economic zones have carried that headline incentive since their regulatory frameworks took effect in April 2026 — but on 7 August […]

ZATCA Transfer Pricing Audits — What Triggers a Review and How to Defend Your Position

May 28, 2026  ·  Tax Topics, Transfer Pricing

Part of the Transfer Pricing in Saudi Arabia: The Complete Guide — Article 6 of 6 01 ZATCA TP Audits: A Maturing Enforcement Environment ZATCA’s approach to transfer pricing enforcement has changed materially since the Bylaws were introduced in 2019. TP is no longer an area where a perfunctory Disclosure Form and a brief description […]

Intercompany Financing and Transfer Pricing in Saudi Arabia — Loans, Guarantees, and Cash Pooling

 ·  Tax Topics, Transfer Pricing

Part of the Transfer Pricing in Saudi Arabia: The Complete Guide — Article 5 of 6 01 Intercompany Financing: Two Layers of Risk, One Transaction Intercompany loans, guarantees, and cash pooling arrangements present a unique compliance challenge in Saudi Arabia: they attract scrutiny under two separate regulatory frameworks simultaneously. Transfer pricing rules determine whether the […]

Intercompany Services and Management Fees in Saudi Arabia — TP Compliance for Intragroup Charges

 ·  Tax Topics, Transfer Pricing

Part of the Transfer Pricing in Saudi Arabia: The Complete Guide — Article 4 of 6 01 Management Fees and Intercompany Services: The Most Scrutinised Transaction in Saudi TP Management fees and intragroup service charges are among the most common related-party transactions involving Saudi entities — and among the most scrutinised by ZATCA. The combination […]