In brief
ZATCA's deemed supplier rules under Article 47 of the VAT Implementing Regulations were amended in 2025 (most changes effective 18 April 2025), with a further scope expansion under Article 47(3) effective 1 January 2026.
If you run an online marketplace connecting sellers to customers in Saudi Arabia, ZATCA may already be treating you as the one legally responsible for VAT on those sales — not the sellers actually listed on your platform. This is the “deemed supplier” rule, and a significant expansion of its scope came into effect on 1 January 2026. If your platform hasn’t reassessed its VAT obligations since that date, this is worth doing now.
What Actually Changed, and When
ZATCA approved amendments to Article 47 (persons obligated to pay tax in special cases) of the VAT Implementing Regulations in 2025. Most of these changes took effect on 18 April 2025. A further, more significant expansion under Article 47(3) — broadening which platforms fall under the deemed supplier rules — became effective 1 January 2026.
On 25 December 2025, ZATCA issued dedicated guidelines clarifying exactly how the deemed supplier rules apply to online marketplace (OMP) businesses, ahead of the January 2026 expansion taking hold.
What “Deemed Supplier” Actually Means
ZATCA’s guidance describes an online marketplace as a digital platform or network that connects and enables transactions between groups of users through technological infrastructure. Where the deemed supplier provision applies, the platform itself — not the underlying seller using it — becomes responsible for VAT on the transaction. In practical terms, the platform must:
- Charge and collect VAT on the sale as if it were the seller
- Issue VAT-compliant tax invoices for the transaction
- Report and remit the VAT collected to ZATCA
- Retain the required VAT documentation for the transaction
This shifts real compliance weight onto the platform operator, even though the platform never took ownership of the goods or service being sold.
How the Platform’s Own VAT Position Works
ZATCA’s December 2025 guidance clarifies a specific mechanic that trips up platforms new to this rule: the platform’s own margin, for deemed supply purposes, is the difference between the price it pays to acquire the goods or service and the resale price charged to the end customer. Because VAT is already embedded in that resale price charged to the customer, the platform does not separately charge VAT on its own commission to the primary (underlying) supplier — doing so would effectively double-count the tax on the same transaction.
Who Needs to Reassess Their Position
The January 2026 expansion of Article 47(3) broadened which platforms fall under these rules — meaning a marketplace that was outside scope under the pre-2026 framework may now be inside it. Any business operating a digital platform that facilitates sales between third-party sellers and customers in Saudi Arabia — not just large, well-known e-commerce marketplaces — should treat this as a trigger to reassess, rather than assuming the rules only apply to major platforms.
This applies whether the underlying sellers are based in Saudi Arabia or abroad; the deemed supplier mechanism is specifically designed to capture VAT on sales facilitated through a platform regardless of where the seller behind the listing is located.
Key takeaways
- ZATCA's deemed supplier rules under Article 47 of the VAT Implementing Regulations were amended in 2025 (most changes effective 18 April 2025), with a further scope expansion under Article 47(3) effective 1 January 2026.
- Where the rule applies, the platform — not the underlying seller — is responsible for charging, invoicing, reporting, and remitting VAT on the facilitated transaction.
- The platform's own margin is the difference between its acquisition price and resale price; it does not separately charge VAT on its commission, since VAT is already embedded in the customer-facing resale price.
- The January 2026 expansion widened which platforms are in scope — a marketplace previously outside the rules should reassess, not assume the position is unchanged.
- The rule applies regardless of whether the underlying seller is based in Saudi Arabia or abroad.
Frequently asked questions
What is the deemed supplier rule for online marketplaces in Saudi Arabia?
A VAT rule under Article 47 of the VAT Implementing Regulations where, in qualifying circumstances, the online marketplace platform itself — not the underlying seller — becomes responsible for charging, collecting, and remitting VAT on a facilitated sale.
When did the latest changes to the deemed supplier rules take effect?
Most Article 47 amendments took effect 18 April 2025. A further expansion under Article 47(3), broadening which platforms are covered, became effective 1 January 2026, with ZATCA issuing dedicated clarification guidelines on 25 December 2025.
Does a marketplace charge VAT on its own commission when the deemed supplier rule applies?
No. Per ZATCA's guidance, the platform's margin for deemed supply purposes is the difference between its acquisition price and the resale price to the customer — VAT is already embedded in that resale price, so the platform does not separately charge VAT on its commission to the underlying supplier.
Does the deemed supplier rule apply if the underlying seller is based outside Saudi Arabia?
Yes. The rule is designed to capture VAT on sales facilitated through a platform regardless of where the seller behind the listing is located, as long as the marketplace is facilitating a transaction connected to customers in Saudi Arabia.
Which platforms need to reassess their VAT position after the January 2026 changes?
Any digital platform that connects third-party sellers with customers in Saudi Arabia — not only large, established e-commerce marketplaces. The 1 January 2026 expansion of Article 47(3) broadened the scope of covered platforms, so a business previously outside scope should not assume that's still the case.
Sources
- ZATCA — Amendments to the Implementing Regulation of VATofficial amendments document, Article 47 changes
- KPMG — Saudi Arabia Updated VAT on Deemed Suppliers Guidelinesreporting on the 25 December 2025 ZATCA guidance and margin mechanic
- KPMG Saudi Arabia — VAT Guideline for Persons Obligated to Pay Tax in Special Casesdeemed supplier framework overview
- Grant Thornton — VAT and Electronic Marketplaces in Saudi Arabiaplatform obligations under the deemed supplier rules
This article is based on ZATCA's official amendments to the VAT Implementing Regulations and its 25 December 2025 clarification guidelines on deemed supplier obligations, cross-checked against reporting from KPMG and Grant Thornton. Whether a specific platform falls within scope depends on its facts and should be confirmed with ZATCA or a licensed advisor. This article does not constitute tax advice. dariba.co is an independent platform with no consulting relationships.
