Real Estate Transaction Tax

RETT Record-Keeping and Representatives: Article 11(f) and (g) Explained

Both seller and buyer must keep the documents behind every real estate transaction, inside the Kingdom, for at least five years. For conditional exemptions, five years is the legal minimum, not a safe period. Article 11(g) applies the same duties to anyone acting for someone else.

Updated 5 October 20264 min read

Part of RETT in Saudi Arabia: The Complete Guide

Provisions
Article 11(f) and 11(g), RETT Implementing Regulations
Who
Transferor, transferee, or either's representative
Where
In the Kingdom, physically or via server access
How long
5 years from the transaction (or longer under other laws)

In brief

The transferor, transferee or either's representative must keep title or informal documents, payment records, documents proving value and tax, documents proving that exemption criteria were met, and commercial books where required. Records must be held in the Kingdom, physically or through access to the server where they are stored, protected against tampering, for five years from the transaction. Guardians, trustees, custodians, agents, liquidators, receivers, bankruptcy trustees, the guardianship authority and the General Authority for Awqaf must comply when acting for others.

When ZATCA examines a transaction or tests an exemption years later, it asks for proof. Article 11(f) sets out what you must keep, where and for how long. Article 11(g) makes sure that people acting for others, such as guardians, liquidators and endowment administrators, carry the same obligations.

The Provision: Exact Text

What It Means in Plain English

RETT record keeping means that seller and buyer must each keep the deed, payment proof, valuation evidence, exemption evidence and, where required, commercial books for every real estate transaction. The records must be held in Saudi Arabia, protected against tampering, for at least five years. Anyone acting for someone else must keep the same records.

What to Keep

CategoryExamples
Title and transaction documentsNotarized deed, sale contract, usufruct agreement, BOOT contract, informal agreements
Payment recordsBank transfers, ZATCA invoice and payment confirmation, escrow statements
Value and taxAccredited valuations, comparables, allocation of mixed consideration, the RETT registration
Exemption evidenceFamily records (gifts), inheritance deed, waqf registration, share registers (lock-ups), audit reports (Article 3(a)(11)), licences (off-plan)
Commercial booksAccounting records for persons required to keep them

Where and How

Records must be in the Kingdom, either as physical documents or through access to the server holding them electronically. They must be protected by security controls against tampering. If your group’s document system is hosted abroad, make sure the access arrangements meet this requirement.

How Long: The Five-Year Minimum

The legal minimum is five years from the transaction. Treat that as a floor:

  • Conditional exemptions with five-year lock-ups (Articles 3(a)(11), (13), (16), (17), (18), (20)) can be breached in year five. Under Article 8(E), ZATCA’s right to assess a breach is not time-limited.
  • For undisclosed transactions, the three-year assessment window runs from ZATCA’s knowledge (Article 8(D)).

Recommended practice: keep records for five years after the end of any condition period, or ten years from the transaction for conditional exemptions.

Article 11(g): Representatives

Anyone acting for another person must comply with Article 11: registration, correction, cooperation with examinations and record keeping. The list includes:

  • guardians and trustees (for minors and others lacking capacity);
  • custodians and agents;
  • supervisors (for example, the nazir of a waqf);
  • liquidators, judicial receivers and bankruptcy trustees;
  • the guardianship authority for minors’ funds; and
  • the General Authority for Awqaf.

This is consistent with Article 1’s definition of “Representative”.

Worked Examples

Example 1: Intra-group transfer

A group transfers land under Article 3(a)(18) in 2026. It keeps the deed, the RETT notice, valuations, structure charts and annual share registers until 2036, five years after the lock-up ends in 2031.

Example 2: Guardian sale

A court-appointed guardian sells a minor’s inherited apartment. The guardian registers the transaction, pays the RETT from the minor’s funds, and keeps the court authority, deed and payment records for at least five years.

Common Mistakes

  • Buyers assuming record keeping is the seller’s job. Both parties are covered.
  • Deleting records at year five while exemption conditions are still running.
  • Storing records abroad without access from the Kingdom.

The Bottom Line

Article 11(f) is simple to comply with and costly to ignore. Without records, a valid exemption becomes hard to prove and a fair price becomes hard to defend. Keep the file, keep it in the Kingdom, and keep it until well after any condition period ends.

Key takeaways

  1. Both the transferor and the transferee, or either's representative, must keep RETT records.
  2. Required records: deeds or informal documents, payment records, documents proving the value and the tax, documents proving exemption criteria were met, and commercial books where required.
  3. Records must be kept in the Kingdom, physically or through access to the server where they are stored electronically, with controls against tampering.
  4. The retention period is five years from the transaction, unless another law requires longer.
  5. For conditional exemptions with five-year conditions, and given ZATCA's unlimited right to assess breaches, keep records for at least five years after the condition period ends.
  6. Guardians, trustees, custodians, agents, liquidators, receivers, bankruptcy trustees, the guardianship authority and the General Authority for Awqaf must meet these obligations when acting for others.

Frequently asked questions

How long must I keep RETT records in Saudi Arabia?

At least five years from the date of the real estate transaction, unless another law requires longer (Article 11(f)(3) of the RETT Implementing Regulations). For transactions under conditional exemptions, keeping records until five years after the condition period ends is the safer approach.

Does the buyer also have to keep RETT records?

Yes. Article 11(f)(1) applies to the transferor, the transferee, or the representative of either. Buyers should keep the deed, the RETT notice and payment evidence, and anything proving exemption conditions they are responsible for.

Can RETT records be kept on a cloud server outside Saudi Arabia?

Records must be kept in the Kingdom, either physically or by providing access to the server where they are stored electronically, with security controls against tampering (Article 11(f)(2)). Confirm that your arrangement gives access from within the Kingdom and meets any other data-location rules.

Do these rules apply to a guardian selling property for a minor?

Yes. Article 11(g) requires guardians, trustees, custodians, agents, supervisors, liquidators, judicial receivers, bankruptcy trustees, the guardianship authority for minors and the General Authority for Awqaf to comply with Article 11's obligations when acting on behalf of others.

Sources

Free toolRETT Exemption Checker

Based on the RETT Law (Royal Decree No. M/84, effective 10 April 2025), the RETT Implementing Regulations (ZATCA Board Resolution No. 01-03-25 dated 24 March 2025, unofficial English translation; Article 11(g) text reconstructed from a garbled line break in the translation) and ZATCA's Detailed RETT Guideline Version 6 (May 2026). The Arabic text prevails. This article is general information, not advice on any specific transaction. dariba.co is an independent knowledge platform and is not affiliated with ZATCA.