Saudi Arabia's General Authority for Zakat and Tax (GAZT) has published Transfer Pricing Guidelines to provide insight and guidance on the transfer pricing practice of Saudi Arabia and the GAZT's views on the application of the country's new Transfer Pricing Bylaws ({News-2019-02-21/A/4-previous coverage}). The Guidelines cover a broad range of topics, including:

• What is transfer pricing;
• Subjects within the scope of the Transfer Pricing Bylaws;
• Comparability analysis: identification and determination;
• Transfer pricing documentation, including:
  • General documentation;
  • Master file;
  • Local file;
  • Country-by-Country (CbC) report;
  • Disclosure Form of Controlled Transactions (part of annual return); and
  • CbC Notification (part of annual return);
• Implementation of the arm's length principle;
• Specific guidance on:
  • Financial transactions;
  • Intangibles; and
  • Business restructuring;
• Valuation;
• Permanent establishments; and
• Audit and risk assessments.

The Guidelines also note that for any issued not addressed in the Guidelines, the OECD Transfer Pricing Guidelines may be referred to. However, any material or documents issued by the GAZT supersede any other source on transfer pricing, including the OECD Guidelines.