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
Contents
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
Continue Reading
Access Full Content
You're viewing a preview of this document. Please log in to unlock the complete content, annotations, and research tools.
Click here to view details of the free plan and the subscriptions we offer.