Saudi TP Disclosure Form and Accountant Certificate

Disclosure is different from preparing the files

Amended TP Bylaws Article 14 requires the prescribed disclosure information with the taxpayer’s return and its separate accountant certificate. Articles 16–19 address the Master/Local File obligations and exceptions. A business below a file threshold should not assume that it has no disclosure or pricing obligations.

ZATCA’s Arabic Transfer Pricing Guideline, third edition 2024, section 5.6 and the disclosure-user guidance in its annexes explain the form. Mixed companies are treated as income-tax persons in full for this TP purpose. The review should cover the actual controlled dealings rather than only the percentage attributed to foreign shareholders.

Build the inventory from actual dealings

Article 14 addresses the related persons, group or taxpayer restructuring, beneficial and legal ownership, financial information, relationship, transaction category, amounts, pricing method, non-monetary dealings, business segment and document-maintenance position. Link that information to the actual relationship map and accounts.

Dariba recommends searching beyond the related-party expense ledger: asset transfers, financial arrangements, rights, free services and restructurings may require analysis even where no ordinary supplier invoice exists. The related-person guide explains why a list limited to shareholders or overseas payees can miss a controlled transaction.

Select the category based on actual character

Guideline section 5.6.1 distinguishes tangible, intangible, service and financial transactions. It directs classification by the actual characteristics, conduct and purpose rather than the name alone. For a genuinely inseparable mixed transaction, the principal purpose and explanation of incidental components matter.

The same section states that the financial transaction value field concerns interest expense or margins rather than financing principal. Keep the underlying loan balance and terms in the analysis even where the particular form field uses a different amount. Do not assume that one form-field convention automatically settles every statutory valuation or threshold question.

Nil consideration does not mean no transaction

Article 14(a)(8) requires disclosure of transactions without consideration or with non-monetary consideration during the relevant year, with the stated annual arm’s-length value information where applicable. A free management service, nominal licence or in-kind transfer can therefore need review even when its accounting expense is zero.

Dariba illustration: suppose a related enterprise supplies a documented service without charging cash. The absence of payment does not establish that nothing needs disclosure or that an arm’s-length value is nil. Identify the actual service, benefit, legal conditions and valuation basis. This is an original factual illustration, not an official ZATCA valuation or instruction to invent an unsupported charge.

Reconcile the 120-day submission and required information

Article 14(b) states the disclosure period as no more than 120 days after the taxpayer’s relevant tax/Zakat year end. The form should agree with the year’s actual transactions, accounts and adjustments. Keep the submission and attachments so the delivered version can be compared with the reviewed version.

Section 5.6.1’s footnote explains that a missing technical field does not excuse omission of required information; relevant additional information should be supplied through the available supplementary route. A portal limitation should therefore be resolved and documented, rather than treated as authority to leave out a material restructuring or transaction detail.

Understand what the accountant certificate actually states

Article 14(c) requires a certificate from an accountant licensed in the Kingdom concerning application of the group’s followed TP policy in relation to the taxpayer’s Saudi dealings. Establish the exact required statement and supporting work. A policy document that was never implemented does not establish that the condition is satisfied.

The certificate is not a universal independent certification that every controlled price is arm’s length or that all comparables and tax consequences are legally settled. The taxpayer remains responsible for the actual information and support. Dariba recommends reconciling policy, agreements, actual charge calculations and financial results before requesting the signature.

Keep country notification and document requests separate

Article 18’s country-report notification is a separate obligation with its own group threshold, reporting-entity information and 120-day rule. The country report itself has the distinct 12-month deadline. Completing the controlled-transaction form does not independently demonstrate that the country-report obligations have been met.

Likewise, the Master and Local Files generally remain available for the applicable request process; their submission deadline is the period specified by ZATCA, at least 30 days from its request under the relevant articles. The documentation guide explains why neither the 2019 temporary extension nor a copied fixed 30-day statement supplies every current deadline.

Review the completed return as a connected evidence file

Check the related-person identities, residence, transaction categories, values, non-cash dealings, methods, restructuring, file status and accountant certificate against the supporting records. Where there were no identified controlled dealings, establish the actual return/form requirements and document the relationship review; do not confuse no cash payment with no transaction.

The TP overview explains the wider pricing process. A disclosure form is valuable because it exposes the taxpayer’s actual position clearly. Filing it is not approval of that position, a guarantee that no questions will follow or a substitute for analysing the arrangement before entering into it.