Saudi TP Documentation: Files, Thresholds and Deadlines

Keep five different obligations distinct

The amended TP Bylaws distinguish the Article 14 disclosure form and accountant certificate, Article 15 supporting evidence, Article 16 Master File, Article 17 Local File and Article 18 country-by-country reporting. An exemption from specified files does not automatically remove the other requirements or the arm’s-length principle.

Use the current Arabic Bylaws with Board Decision 8-2-23 and ZATCA’s Arabic Transfer Pricing Guideline, third edition 2024, chapter 5 and Annex 7. The English November 2021 guideline predates the Zakat extension. Its old scope and thresholds should not be presented as the complete current framework.

Apply the ordinary CIT and mixed-company threshold

Article 1’s small-enterprise definition uses an arm’s-length value of controlled transactions not exceeding SAR 6 million in a 12-month period for CIT or mixed taxpayers. Article 19 identifies the relevant file exceptions. Exactly SAR 6 million falls within “not exceeding”; the ordinary threshold is crossed above it.

Assess the appropriate aggregate value and period rather than testing each invoice separately or netting receipts against payments without support. The separate Zakat-only phases do not replace the SAR 6 million route for a mixed taxpayer merely because most of its ownership is Saudi. Disclosure and general evidence remain separate questions.

Preserve the Zakat-only phases and equality boundaries

Decision 8-2-23 applies the Zakat extension to years beginning on or after 1 January 2024 and phases the Article 16–17 file requirements:

For ordinary financial years beginning in 2024–2026, use the first phase; years beginning on or after 1 January 2027 engage the second. Exactly SAR 100 million is included in the mandatory first-phase band; exactly SAR 48 million remains outside the higher band. Establish the year-start date rather than switching every taxpayer’s treatment on a transaction date during 2027.

Financing funds and consolidated groups need their own paragraph

The decision excludes financing funds from the first phase and includes them in the second. Do not turn that particular file treatment into an exemption from every TP obligation. Country reporting, disclosure, general support and the underlying pricing rules must be tested separately.

Article 19(c) addresses companies filing a unified Zakat return under the relevant Zakat rules and their dealings within that group. Dealings with companies owned below 100% remain subject to the stated disclosure and documentation treatment. Accounting consolidation alone does not establish the unified-return condition. The Zakat group guide explains that distinct eligibility question.

Prepare useful Master and Local Files

Article 16’s Master File describes the multinational group’s structure, business, value chain, intangibles, financing and financial/tax position. Article 17’s Local File addresses the taxpayer, controlled transactions, functions, risks, method, comparables and financial reconciliation. The files should explain one consistent factual and economic story.

The 2024 guideline, sections 5.3.1–5.3.2, discusses the complementary documents and the actual circumstances where sufficient detail may be assembled for multiple taxpayers. A group template without the Saudi transaction analysis is not a completed Local File. Likewise, assess the actual multinational-group context of the Master File instead of creating fictional foreign activities for a domestic business.

A request period is at least 30 days, not always exactly 30

Articles 15–17 require the documents within the period ZATCA specifies, which must not be less than 30 days from the request date. Keep the actual request and calculate its actual deadline. A statement that every request is invariably due in exactly 30 days is too restrictive; waiting for the request before reconstructing the year’s evidence is nevertheless risky.

Article 19(b) also permits specified documentary requests despite exceptions, including relevant special-zone or exempt-counterparty dealings, avoidance concerns, corresponding-adjustment requests and international obligations. The threshold is therefore not a promise that no evidence can ever be requested. The guideline, sections 5.2–5.3, preserves general documentation for exempt persons.

Country reporting has its own threshold and clocks

Article 18 addresses multinational groups exceeding SAR 3.2 billion of consolidated revenue in the preceding relevant year, with the prescribed reporting role, local-filing conditions and notification. The country report is due within 12 months after the reporting year; the Saudi notification has its separate 120-day rule. These requirements are not triggered simply by crossing SAR 6 million of controlled transactions.

Establish the parent or surrogate filing, effective exchange arrangement and any actual local-filing condition before assuming that foreign filing settles the Saudi position. A designated local report can differ from each constituent’s notification. Foreign revenue thresholds and currency rules also require their applicable guidance rather than an improvised current exchange-rate conversion.

Reconcile the documentation before signing the form

Tie the transaction values, related persons, method, financial results and material adjustments to the accounts and Article 14 disclosure. Retain the accountant certificate for its actual purpose; it is not independent certification of every arm’s-length price. Article 19 exceptions require their actual categories, including the natural-person/establishment distinction, rather than a blanket natural-person waiver.

The disclosure guide explains nil or non-monetary dealings, restructuring and missing-field information. The commercial value of the documentation is a reviewable conclusion supported by actual facts, rather than a file count that leaves contradictory numbers, omitted related parties or an expired threshold assumption unresolved.