Saudi Arabia Transfer Pricing Reporting Deadlines Approaching

Multinational enterprises (MNEs) with entities in Saudi Arabia face upcoming deadlines for key transfer pricing documentation. The Zakat, Tax and Customs Authority (ZATCA) requires timely preparation and submission of the Transfer Pricing Disclosure Form, Local File, Master File, and Country-by-Country (CbC) Notification.

These compliance obligations impact entities engaged in controlled transactions. The Disclosure Form, along with an affidavit from a licensed accountant certifying consistent application of transfer pricing policy, must be filed with the annual corporate income tax return. Requirements for Local and Master Files apply to entities involved in material related-party transactions exceeding specific thresholds.

For calendar year-end entities (FY2025), the tax return and Disclosure Form are due by April 30, 2026. Local and Master Files must be prepared contemporaneously with the tax return and be ready for submission to ZATCA within 30 days of a request. The CbC Report is due 12 months after year-end, with a dual notification requirement via the Disclosure Form and ZATCA's online portal.

The transfer pricing landscape in Saudi Arabia has evolved significantly since 2019. Increased audit sophistication by ZATCA and a growing body of tax committee rulings indicate a more enforcement-focused environment, requiring careful attention to documentation and compliance requirements.