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TRANSFER PRICING DOCUMENTATION

Transfer Pricing Documentation

Related-party transactions, documented and defensible under ZATCA’s transfer pricing bylaws.

Basis
ZATCA TP Bylaws & OECD Guidelines
Best for
Multinational & group entities
Output
Local file & disclosure forms

Related-party pricing that holds up to review

Saudi Arabia’s transfer pricing bylaws require qualifying entities to prepare disclosure forms and, above certain thresholds, a local file and master file demonstrating that related-party transactions are priced on an arm’s-length basis. The documentation only has value if it can withstand a ZATCA query.

We prepare TP documentation the way we’d want to defend it — with benchmarking data, a clear policy rationale, and language that matches how the business actually operates.

What’s included

  • Transfer Pricing Policy Design
  • Local File Preparation
  • Master File Preparation
  • Related-Party Disclosure Forms
  • Benchmarking Studies
  • Intercompany Agreement Review
  • ZATCA Query Response Support
  • Transfer Pricing Risk Assessment

Quick facts

  • Basis
    ZATCA TP Bylaws & OECD Guidelines
  • Best for
    Multinational & group entities
  • Output
    Local file & disclosure forms
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Common questions

Frequently asked questions

Do we need transfer pricing documentation?
If you have related-party transactions and meet ZATCA’s disclosure thresholds, yes. We assess your specific position first — not every entity needs a full local file, but most groups need at least the disclosure form.
What’s the difference between a local file and a master file?
The local file documents your specific entity’s related-party transactions and pricing. The master file provides a group-wide overview of the multinational’s operations and TP policies. Larger groups typically need both.
How do you benchmark related-party pricing?
We use recognized databases and methodologies to identify comparable arm’s-length transactions or margins, consistent with OECD guidelines and ZATCA’s expectations.
Can you help if ZATCA has already raised a query?
Yes. We support clients responding to existing ZATCA transfer pricing queries, not just building documentation proactively.
How often does TP documentation need to be updated?
Generally annually, or whenever there’s a material change to the business, related-party transactions, or group structure.
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