Transfer Pricing Compliance Reminder – Saudi Arabia Disclosure Form, Local File, Master File, and CbC Notification Deadlines Approaching
Overview
Multinational enterprise (MNE) groups with entities operating in Saudi Arabia should make note of the critical transfer pricing documentation deadlines. The Transfer Pricing Disclosure Form, Local File, Master File, Country-by-Country (CbC) Notification and filing represent core compliance obligations under Saudi Arabia's transfer pricing regulations. These documents must be prepared and submitted in accordance with Zakat, Tax and Customs Authority (ZATCA) requirements.
Who Is Affected?
Transfer Pricing Disclosure Form and Affidavit from a Licensed Accountant
- All entities in Saudi Arabia that have engaged in controlled transactions during the fiscal year.
- Includes a confirmation statement indicating whether Master and Local files are maintained at the time of filing the transfer pricing disclosure form.
- Must be filed as an attachment to the annual corporate income tax return, along with an affidavit from a licensed accountant in Saudi Arabia certifying consistent application of the transfer pricing policy.
Local File
- Entities engaged in material related party transactions (exceeding SAR 6 million in aggregate for mixed and tax paying entities, and SAR 100 million for 100% Zakat paying entities).
Master File
- Groups engaged in material related party transactions with KSA-domiciled related parties (exceeding SAR 6 million in aggregate for mixed and tax paying entities, and SAR 100 million for 100% Zakat paying entities).
CbC Notification
- All Saudi Constituent Entities of MNE groups meeting the SAR 3.2 billion consolidated revenue threshold.
- Required for entities that are a part of groups subject to CbC Reporting requirements.
- Dual CbC notifications are required in Saudi Arabia, one as part of the Transfer Pricing Disclosure Form and other on Automatic Exchange of Information (AEOI) portal of ZATCA.
Key Deadlines
| Document | Filing Deadline | Threshold | Notes |
|---|---|---|---|
| Transfer Pricing Disclosure Form and Affidavit from Licensed Accountant | With the tax return (120 days after year-end) | No threshold | Mandatory attachment for all entities with related-party transactions |
| Local File | Within 30 days of ZATCA’s request | SAR 6 million aggregated related-party transactions (taxpayers and mixed entities) SAR 100 million for 100% Zakat entities (Reduced to SAR 48 million for Zakat payers from FY27) | Must be prepared by the tax return filing deadline and submitted upon request |
| Master File | Within 30 days of ZATCA’s request | SAR 6 million aggregated related-party transactions (taxpayers and mixed entities) SAR 100 million for 100% Zakat entities (Reduced to SAR 48 million for Zakat payers from FY27) | Must be prepared by the tax return filing deadline and submitted upon request |
| Country-by-Country (CbC) Report | 12 months after year-end | SAR 3.2 billion consolidated group revenue | Mandatory for KSA-headquartered groups exceeding SAR 3.2 billion in consolidated revenue |
| CbC Notification | With the tax return (120 days after year-end) Second notification required online | SAR 3.2 billion consolidated group revenue | Must be submitted both via the Disclosure Form with the tax return and on the online portal within 120 days after year-end Disclosure Form as well as on the online portal |
For calendar year-end entities (FY2025), the Zakat/tax return and Transfer Pricing Disclosure Form are due by April 30, 2026 (i.e. 120 days from financial year end), while the Local and Master Files must be maintained contemporaneously with the Zakat/tax return and ready for submission, if requested by ZATCA. Entities will be provided with a 30-day time frame to furnish Master File and Local file.
