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
- Transfer pricing now applies to Zakat payers
- Parent charges IT services to Saudi subsidiary
- Auditor affidavit for TP disclosure
- CbCR threshold check
- Deadline to give Master File after request
- No specific TP penalty but general penalties apply
- Interest-free loan from shareholder company
- Advance pricing agreement eligibility
- Intercompany agreement missing
- CbCR notification by local entity
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.