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May 15, 2026

This ZATCA guideline details the framework for Advance Pricing Agreements (APAs) in the Kingdom of Saudi Arabia, primarily implementing Article 23 of the Transfer Pricing (TP) Bylaws. It aims to provide taxpayers with tax certainty and proactively prevent future TP disputes. The guide outlines the eligibility criteria, application procedures, and processing stages for unilateral APAs, which is currently the only type available. It covers the scope of agreements, the role of critical assumptions, and the typical APA period of three years. Furthermore, it specifies ongoing taxpayer obligations, including submitting an Annual Compliance Report and outlines processes for revision and renewal.

Advance Pricing Agreements

Zakat, Tax and Customs Authority

First Version | February 2025

Part 1 - Introduction

1. Definitions
2. Introduction
3. Purpose of this Guideline
4. Related provisions
5. Who is eligible to submit an APA application
6. Expected co-operation from taxpayer(s)
7. Persons authorized to sign the APA agreement

Part 2 - Advance Pricing Agreement

8. Types & Benefits of APAs
9. Scope of the Agreement
10. APA period
11. Critical Assumptions

Part 3 - APA request

12. Advance pricing agreement procedures
13. Submission of the APA application
14. Introductory meeting

Part 4 - Processing the APA request

15. APA request Processing
16. Application review, analysis and evaluation phase
17. Conclusion of APA request
18. Rejection of the application
19. Withdrawal from the APA request

Part 5 - Advance Pricing Agreement Management

20. Submit an APA Annual Compliance Report
21. Annual review of the Taxpayer's compliance with the Agreement
22. Compensating Adjustments
23. Addressing disputes
24. Revision of the APA
25. Cancellation or termination of the APA
26. Revocation of the APA
27. Renewal of the APA

Appendix

Appendix 1 - Unilateral APA Application

The Zakat, Tax and Customs Authority ("ZATCA", "Authority") has issued these Tax Guidelines for the purpose of clarifying certain tax treatments concerning the implementation of the statutory provisions in force as of the Guideline's issue date. The content of these Guidelines shall not be considered as an amendment to any of the provisions of the Laws and Regulations applicable in the Kingdom.

Furthermore, the Authority would like to highlight that the clarifications and indicative tax treatments prescribed in these Guidelines, where applicable, shall be implemented by the Authority in light of the relevant statutory texts. Where any clarification, interpretation or content provided in these Guidelines is modified - in relation to unchanged statutory text - the updated indicative tax treatment shall then be applicable prospectively, in respect of Transactions made after the publication date of the updated version of the Guidelines on the Authority's website.

Part 1 - Introduction

1. Definitions

1.1. "Advance Pricing Agreement" or "APA"

Contents

Part 1 - Introduction