In May 2020, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has released the second edition of Transfer Pricing Guidelines (translated version). The Guidelines includes most of the section of the first edition, which was released in March 2019 after the release of the final transfer pricing bylaws in February 2019. The Guidelines includes the following:
- added the definition of Authorized OECD Approach, Ownership Beneficial, De facto owner of intangibles, and Group.
- states that there is no materiality threshold for the applicability of the arm’s length principle on controlled transactions
- the implementation process of audits and assessments
- procedures for transfer pricing documentation and country-by-country (CbC) reporting
- transfer pricing form
The goal of publishing the Guidelines is to minimize any ambiguities for taxpayers in the country on the implementation and application of the local transfer pricing legislation.
