Saudi Marketplace VAT: Deemed Supplier Rules and Exceptions

Article 47 can treat an online marketplace as purchasing an underlying supply and reselling it in its own name. The result is transaction-specific. Supplier residence and registration, the marketplace’s actual role, the nature/place of the supply and the applicable exception all matter. A platform label or commission agreement alone does not decide who accounts for Saudi VAT.

Read the different Article 47 rules separately

Article 47(1) concerns reverse charge on qualifying supplies received from non-residents. Paragraph (2) addresses services facilitated electronically in the Kingdom through a marketplace acting for non-resident suppliers. Paragraph (3) addresses goods/services facilitated for resident suppliers not registered for VAT. Paragraph (4) defines the marketplace and the limited activities that do not constitute facilitation.

Paragraph (5) concerns a separate business-transfer liability rule; it is not another universal marketplace charging rule. See the business-transfer analysis.

ZATCA’s official Persons Liable to Pay Tax in Special Cases – Deemed Suppliers guideline, as retrieved on 22 October 2026, provides the detailed examples used here. Section 11, p. 74, explains that the non-resident electronic-services framework has applied since 2018, with clarifying amendments. The resident-unregistered expansion applies to customer contracts/agreements concluded from 1 January 2026. Do not describe every platform transaction as newly brought into scope on that date.

Establish whether the marketplace actually facilitates

Article 47(4)(b) includes platforms with a main purpose of enabling suppliers to display, provide, make available or contract for products with customers. Paragraph (4)(a) excludes a role limited to payment processing, advertising without facilitating the supply, or redirecting the customer to another marketplace that facilitates it.

The guideline sections 4–5, pp. 10–18, examines actual control over ordering, terms/prices, fulfilment, payments, complaints and the platform’s presentation. The contract must reflect commercial practice; an agent label is not conclusive.

Official comparison: section 5, Example 1, pp. 15–16, treats RiyadhCar as facilitating unregistered resident drivers’ rides because it manages bookings, fares, assignments, payments and complaints. Section 5.1, Example 2, pp. 17–18, treats SafeRide differently: it lists driver details for a monthly subscription, while passengers contact, negotiate and pay drivers directly. It does not facilitate the underlying ride on those facts.

Dariba analysis: absence of direct payment collection is not by itself enough to escape the rule. Conversely, a genuine payment-only service is not equivalent to a platform managing the whole sale. Review the actual combination of functions rather than counting isolated website features.

Apply the non-resident services rule with the correct boundary

Current Arabic Article 47(2) refers to services facilitated electronically through the marketplace. The English guideline’s section 6, pp. 19–27, focuses on electronically supplied services. Its section 6.1 includes downloads, SaaS, streaming and relevant remotely delivered professional/support services; it distinguishes services requiring physical presence from electronic delivery.

Section 6.1, Example 4, p. 22, describes ArtistHub distributing downloadable designs from UK supplier ArtisticVisions. The platform facilitates the sale, verifies the supplier’s non-resident status and treats itself as deemed supplier to Saudi consumers on the stated facts.

Do not extend that example to all foreign goods or every physically performed service booked online without analysing the controlling Arabic wording, service characteristics and place. Equally, the English guideline’s narrower terminology should not be used as permission to disregard the Arabic provision. For an arrangement falling outside the examples, identify the precise unresolved issue before deciding the reporting position.

The two exceptions have different statutory conditions

Article 47(2)‘s exception requires both its stated limbs: clear identification of the non-resident underlying supplier throughout the supply, contracts, invoice and receipt; and the marketplace not undertaking the specified control over terms, price, charging/collection, complaints, offers or compensation.

Article 47(3)‘s exception has three limbs. In addition to supplier identification and the limited marketplace role, it expressly requires an independent, direct supplier/customer contractual relationship, with the resident unregistered supplier setting the terms. That additional statutory limb should not be copied into paragraph (2) as if both paragraphs contain identical three-part wording.

The guideline section 6.3, pp. 24–25, and section 7.3, pp. 38–40, explain the respective conditions. Page 40 specifically identifies the additional resident-supplier relationship requirement. Section 6.3 also accepts a complaints mailbox that merely forwards messages while the supplier substantively resolves them; this differs from the marketplace deciding complaints.

An exception must be supported in practice, not just by disclosing a seller’s name. If the platform sets binding prices or handles refunds, assess the actual statutory effect. Do not assert that every communication with a customer necessarily defeats the exception or that paperwork alone establishes it.

Resident unregistered sellers are different from registered sellers

For Article 47(3), verify both residence and a valid, active VAT registration at the relevant supply time. A seller saying turnover is small does not decide the platform’s obligation. A valid registration can change the model for that seller; it does not prove every other seller has the same status.

The guideline section 7.2, Example 6, pp. 35–36, gives Fatima’s pottery sold through Crafty for SAR 1,800 excluding VAT. Crafty invoices the customer SAR 2,070, including SAR 270 VAT, and pays Fatima SAR 1,620 after the stated 10% commission. It is deemed to purchase and resell the pottery. The underlying unregistered purchase does not generate input VAT for Crafty.

Example 7, pp. 36–37, changes the treatment after Hamza registers: he invoices the customer for his own supply, and Bazaar separately invoices its actual platform/delivery/additional services. The same app can therefore need more than one VAT workflow.

Separate purchase, resale and the platform’s own services

The guideline section 8.2, pp. 46–54, requires the customer resale and deemed purchase to be analysed separately. The relevant customer-facing taxable value is not merely the platform’s retained margin.

In Crafty’s example, the SAR 180 commercial difference between the SAR 1,800 net resale price and SAR 1,620 purchase is already within the resale. It is not another separately taxable commission for that same facilitation. This does not turn the whole resale into VAT on margin alone. Nor does it exempt independent subscriptions, advertising, storage or other genuine separate services.

Example 7 specifically distinguishes transaction-related commission/delivery included in the customer price from additional services requiring a separate invoice. Review what each charge buys, to whom it is supplied and whether it is part of the facilitated supply. The name “service fee” cannot decide the answer by itself.

A deemed supplier does not universally remove reverse charge

The guideline’s tables in sections 6.2 and 7.2, pp. 23 and 34, distinguish resident and non-resident marketplaces and the customer’s status. A resident marketplace can need reverse charge on its deemed purchase of non-resident services and output VAT on its onward supply. A non-resident marketplace supplying a Saudi registered taxable customer can leave that customer responsible for reverse charge on the actual received supply.

A foreign platform’s invoice showing a tax-like amount is not enough to switch reverse charge off or establish deductible Saudi VAT. Determine the actual supplier, place, customer status and lawful charging treatment. Correct an incorrectly charged amount through the appropriate route rather than claiming it automatically as input VAT or reporting the same liability twice.

See the reverse-charge guide and operating checklist for reporting and reconciliation. Normal entitlement restrictions remain relevant even where a return system initially calculates equal reverse-charge input and output amounts.

Keep the transaction evidence current

The guideline section 7.5, p. 42, requires reasonable verification of supplier residence/registration at onboarding and at supply as necessary, with actual practice matching contracts. Preserve identity evidence, active TIN checks, terms, order/payment records, invoices, settlement statements and any exception analysis.

Reassess when registration, residence, fulfilment or complaint handling changes. A one-time onboarding declaration does not establish the position for every future sale. Genuine principal sales and own-name agency under Article 9 of the VAT Law must also be considered even where a particular Article 47 deeming provision does not apply.