Advance pricing agreement eligibility
Can we get an APA with ZATCA?
The situation
Public guides report that APA applicants need annual related party transactions of at least SAR 100 million.
The law
- ZATCA Transfer Pricing Bylaws (15 February 2019, amended 7 April 2023): Arm's length rule; from years starting 1 January 2024 also applies to Zakat payers
What it means for you
An APA gives certainty on pricing for future years. Small and mid groups usually rely on good documentation instead. Confirm the current criteria with ZATCA.
What to do
- Check transaction volume.
- Weigh cost against certainty.
- Apply if eligible.
We can do this for youTransfer pricing compliance: disclosure form, auditor affidavit, Master File, Local File and CbCR check: SAR 6,000