In brief
Persons under examination must cooperate with ZATCA. Examinations take place at ZATCA or at the taxpayer's workplace, after at least 20 days' notice. Unannounced examinations need a prior decision of the Governor, based on reasonable suspicion or likely non-cooperation. ZATCA can access and copy books, records and electronic data, remove documents against a receipt, use government and third-party information, enter premises and properties under Governor decisions, and seize documents at risk of being concealed. It must report the results and the reasons for any assessment.
Article 8 gives ZATCA the power to question a value. Article 11(c) gives it the means to investigate one: notice periods, on-site examinations, physical entry to property, and access to data held by other government bodies. Here is what ZATCA can do, and what it must do in return.
The Provision: Exact Text
What It Means in Plain English
A RETT inspection by ZATCA normally comes with 20 days’ notice and takes place at ZATCA’s office or yours, during working hours. ZATCA can review and copy your records, including electronic ones, enter properties involved in transactions, and use data from other agencies. If it suspects a violation or expects non-cooperation, it can act without notice, but only with the Governor’s prior approval.
Your Rights and Obligations
| ZATCA may | ZATCA must |
|---|---|
| Examine at its offices or your workplace (11(c)(1)(a)) | Give at least 20 days’ notice, unless the Governor approves otherwise (1)(a)–(b) |
| Access, examine and copy books, records and invoices (1)(c) | Examine during working hours or at agreed times (1)(c) |
| Remove documents (1)(d) | Give a receipt and return them within 20 days of completion (1)(d)–(e) |
| Obtain data from government, third parties and foreign bodies (2) | Notify you of the results and reasons for any assessment (1)(f) |
| Enter business premises and related third-party premises (4) | Have a prior Governor decision (4) |
| Enter a property subject to a transaction (5) | Have a Governor decision and give 20 days’ notice to the occupant and owner (5) |
| Require paper or electronic copies of system records (6) | Identify the assigned officers, who carry ID (8) |
| Seize documents at risk of concealment, and gather evidence of suspected evasion (7) | Have a prior Governor decision for evasion searches (7) |
You must cooperate, provide access, and produce electronic records in usable form.
Worked Examples
Example 1: Routine valuation examination
ZATCA notifies a developer on 1 March of an examination starting 25 March into five related-party land transfers. The developer prepares its deeds, valuations and payment records and provides electronic copies. ZATCA completes its review on 20 April, returns the removed files by 10 May, and issues a results letter explaining a SAR 80,000 assessment, which the developer may object to.
Example 2: Physical inspection of a property
To check whether a building’s description matched its declared condition at transfer, ZATCA obtains a Governor decision and notifies the tenant and owner 20 days before visiting the occupied areas.
Example 3: Suspected evasion
ZATCA has evidence of side payments on a portfolio sale. With a prior Governor decision, it enters the seller’s offices without notice and temporarily seizes records at risk of being destroyed.
Practical Tips
- Keep an examination-ready file for every transaction: the deed, the RETT notice, the valuation, payment evidence and exemption evidence.
- Ask to see the officers’ identification and, for entry, the Governor’s decision.
- Get receipts for anything removed, and diary the 20-day return deadline.
- Read the results letter carefully. It starts the timetable for any objection.
Common Mistakes
- Treating the notice as optional and being unprepared on day one.
- Producing unreadable or partial electronic data.
- Not documenting what was removed.
The Bottom Line
Article 11(c) gives ZATCA substantial powers to examine transactions, balanced by notice periods, receipts, return deadlines and a duty to explain the results. Organised records are the most effective preparation for an examination.
Key takeaways
- ZATCA must give at least 20 days' notice before an examination, whether at its headquarters or the taxpayer's workplace.
- Examinations without notice need a prior decision of the Governor or his representative, based on reasonable suspicion of a violation or expected non-cooperation.
- On-site examinations take place during working hours or at agreed times. ZATCA may access and copy all required books, records, invoices and documents, including electronic records.
- Removed documents must be receipted and returned within 20 days of completing the examination.
- With a Governor decision, appointed officers may enter business premises, related third-party premises, and any property believed to be subject to a real estate transaction, after 20 days' notice to the occupant and owner.
- ZATCA must notify the taxpayer of the examination's completion, the results and the reasons for any assessment or fine.
Frequently asked questions
Can ZATCA audit my real estate transactions?
Yes. Article 11(c) of the RETT Implementing Regulations allows ZATCA to examine real estate transactions and estimate their value, at its offices or at your workplace. You must cooperate. ZATCA must normally give at least 20 days' notice.
Can ZATCA inspect without notice?
Only with a prior decision of the Governor or his representative, where there are reasonable grounds to suspect a violation, or where the person refuses or is likely to refuse to cooperate (Article 11(c)(1)(b)).
Can ZATCA enter my property?
Yes. Appointed ZATCA officers may enter any property known or believed to be subject to a real estate transaction, under a prior decision of the Governor or his representative. They must give the occupant and owner at least 20 days' notice before entering areas in use (Article 11(c)(5)).
What if ZATCA takes my documents?
ZATCA must give you a receipt for documents removed from your premises and return them within 20 days of completing the examination. It may keep copies (Article 11(c)(1)(d)–(e)). If concealment or tampering is suspected, documents can be temporarily seized and retained.
Where does ZATCA get information for RETT examinations?
From any government body, and from publicly available sources, third parties, international bodies and foreign government entities (Article 11(c)(2)).
Sources
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; minor formatting normalised) 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.