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Saudi Arabia Advance Pricing Agreement Guidelines

14 March 2025

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Approved Changes

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Saudi Arabia

The Saudi Zakat, Tax, and Customs Authority (ZATCA) has released English-language Guidelines on Advance Pricing Agreements (APA) dated February 2025. The guidelines outline the procedures, conditions, and management of unilateral APAs between taxpayers and ZATCA concerning transfer pricing of transactions with related parties. The guidelines also briefly cover bilateral and multilateral APAs but note that ZATCA will not process bilateral or multilateral APAs until further notice. Taxpayers with significant intercompany transactions meeting specific criteria are eligible to apply for an APA, which generally means transactions with a value of at least SAR 100 million. However, complex transactions may be exempted...