Saudi Arabia’s Zakat, Tax and Customs Authority has released guidelines for its new advance pricing agreement (APA) regime.
According to the guidance from the Zakat, Tax and Customs Authority, the program “will not process Bilateral and Multilateral APAs until further notice.”
APAs allow taxpayers to secure certainty on their tax positions for multiple years and the guidance outlines the process for application eligibility and what to do upon acceptance.
An advance pricing agreement between the ZATCA referred to as “the Authority” and a Taxpayer. It covers certain Transactions between the Taxpayer and Related Persons. APAs confirm appropriate Transfer Pricing Methods that will be used to determine the arm’s length price, in advance, and their application to specific Controlled Transactions for specified Zakat/ Tax Years, under specified terms and conditions, in accordance with the provisions of the Tax Law, the TP Bylaws, and TP Guidelines.
Earlier, the Zakat, Tax and Customs Authority (ZATCA) in Saudi Arabia published the third edition of its Transfer Pricing (TP) Guidelines on 29 July 2024.