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Saudi Arabia Publishes Taxpayer Guidance on MAP Requests — Orbitax Tax News & Alerts

Saudi Arabia's General Authority for Zakat and Tax (GAZT) has published Request for Mutual Agreement Procedure – Taxpayer guidance. The purpose of the guidance is to set out the process through which taxpayers can request assistance from the Competent Authority in Saudi Arabia to resolve disputes arising from taxation not in accordance with the provisions of a relevant double taxation agreement (tax treaty). In Saudi Arabia, the Ministry of Finance has delegated this task to the GAZT.

According to the provisions set forth by tax treaties signed by Saudi Arabia and relating to the resolution of difficulties arising where the actions of one or both of the Contracting States result or will result, for the taxpayer, in taxation not in accordance with the provisions of the treaty, GAZT will endeavor to resolve such cases by mutual agreement with the Competent Authority of the other Contracting State. In cases such, taxpayers may request assistance from GAZT to resolve the issue.

For this purpose, the guidance provides an overview of MAP, the conditions for requesting MAP, how to request MAP, the timeframes for resolving MAP cases, and the stages of MAP. This includes that MAP requests are generally required under most of Saudi Arabia's tax treaties within three years from the first notification of action not in accordance with the applicable tax treaty (two years under treaty with Syria), and that cases should be resolved within two years, depending on the complexity of the case.