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May 15, 2026

Issued by GAZT Board Resolution No. 6-1-19 of 1440H, these Transfer Pricing Bylaws establish the legal framework for transactions between related parties in Saudi Arabia. They apply to taxpayers under both the Income Tax Law and Zakat Regulations, mandating adherence to the Arm's Length Principle. The bylaws detail approved pricing methods in Article 7, comparability analysis in Chapter 3, and comprehensive documentation obligations, including the Master File (Article 16), Local File (Article 17), and Country-by-Country Reporting (Article 18). They also provide for Advance Pricing Agreements and corresponding adjustments to ensure compliance.

TRANSFER PRICING BYLAWS

Issued by the General Authority of Zakat and Tax pursuant to Board Resolution NO [6-1-19] DATED 25/05/1440H corresponding to 31/01/2019

Disclaimer: the General Authority of Zakat and Tax warns against the use of and reliance upon regulations, bylaws, and Guidelines other than final approved versions published on the Authority's website www.gazt.gov.sa; the Authority shall not be liable for any loss or damage arising out of the use of unofficial or unapproved documents.

Contents

Chapter 1 - Definitions

Article 1: Definitions

Chapter 2 - Scope of Application

Article 2: Persons Subject to the Bylaws

Article 3: Terms and Conditions of Controlled Transactions

Article 4: Diverging Conditions

Chapter 3 - Comparability

Article 5: Comparable Transactions

Chapter 4 - Approved Methods to Determine an Arm's Length Result of Transactions

Article 6: Transfer Pricing Methods

Article 7: Approved Methods

Article 8: Application of Multiple Methods

Article 9: Use of Methods Other than an Approved Methods

Article 10: Combined Controlled Transactions

Chapter 5 - Arms-Length Range

Article 11: Definitions of Arm's Length Range

Article 12: Adjustments by the Authority

Chapter 6 - Sources of Information

Article 13: Comparable Transactions Information

Chapter 7 - Disclosure Form of the Controlled Transaction

Article 14: Content of Disclosure Form

Chapter 8 - Documentation

Article 15: General Obligations

Article 16: Master File

Article 17: Local File

Article 18: Country-by-Country Report

Article 19: Exceptions

Chapter 9 - Corresponding Adjustments

Article 20: Adjustments in other Countries

Article 21: Corresponding Adjustment Application

Article 22: Determination by the Authority

Chapter 10 - Advance Pricing Agreements

Article 23: Advance Pricing Agreements

Article 24: Audit Procedures

Chapter 11 - Modification and Interpretation

Article 25: Guidelines

Article 26: Interpretation

Chapter 12 - Final provisions

Article 27: General Provisions