Intercompany agreement missing

We never signed agreements with our group companies. Problem?

The situation

TP rules look at the actual conduct and terms of controlled transactions. Written agreements are the main evidence of those terms.

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

Sign agreements that match what actually happens, with services, pricing method and payment terms. Backdating is risky; record the effective date honestly. The auditor will ask for them for the affidavit.

What to do

  1. List flows.
  2. Draft agreements.
  3. Sign and file.

We can do this for youTransfer pricing compliance: disclosure form, auditor affidavit, Master File, Local File and CbCR check: SAR 6,000

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