Transfer pricing compliance: disclosure form, auditor affidavit, Master File, Local File and CbCR check

We list every related party deal, test the prices against arm's length, prepare the disclosure form and auditor affidavit for your return, and tell you if you need a Master File, Local File or CbCR so a ZATCA request never catches you short.

SAR 6,000Annual

For: Taxpayers and, for years starting on or after 1 January 2024, Zakat payers with related party transactions; groups with consolidated revenue above SAR 3.2 billion for CbCR.

What we need from you

  • List of related parties and ownership chart

    Scope

  • Intercompany agreements and invoices

    Nature and value of transactions

  • Group TP policy

    Auditor affidavit on consistent application

  • Total related party transaction value

    Master and Local File threshold

  • Group consolidated revenue

    CbCR test at SAR 3.2 billion

  • Benchmarking studies if any

    Arm's length support

What we discuss

  • Are you a Zakat payer with related party deals?

    From 2024 years TP applies to you too

  • Do related party transactions exceed SAR 6 million a year?

    Master File and Local File must be ready on request

  • Does the group exceed SAR 3.2 billion revenue?

    CbCR notification and report

  • Who is the auditor and can they sign the affidavit?

    Needed with the disclosure form

What we file

  • Related party transaction summary

    Example: management fee SAR 2,000,000 + loan interest SAR 800,000 + goods SAR 5,000,000 = SAR 7,800,000 > SAR 6,000,000, so Master and Local File needed

  • Controlled Transactions Disclosure Form with affidavit

  • CbCR notification

What you get

  • Filed CTDF and affidavit

  • Threshold memo on Master File, Local File and CbCR

  • Gap list on pricing policies

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 Source
  • Transfer Pricing Bylaws, CTDF, Master File and Local File: CTDF with the annual return and auditor affidavit; Master and Local Files within 30 days of request where related party transactions exceed SAR 6 million Source
  • Transfer Pricing Bylaws, Country-by-Country Reporting: Groups with consolidated revenue above SAR 3.2 billion; report within 12 months of year end; notification within 120 days Source

Questions people ask

Contact us to book

Online payment in SAR is not open yet. Send us a message and an adviser for Saudi Arabia confirms the scope and the fee before any work starts.

Sources