Introduction of Unilateral Advance Pricing Agreements

On 19 May 2024, the Zakat, Tax and Customs Authority (ZATCA) publicized the launch of the Unilateral Advance Pricing Agreements (APA) process. This development stems from the recent amendments to the Transfer Pricing Bylaws, specifically incorporating provisions under Article 23. For a detailed overview, please refer to our previous alert on this topic accessible through this link.

Key application details and requirements:

1. Related party transaction value threshold: The transaction value with the related party must be at least SAR 100 million. However, the Governor of the Authority may exempt specific sophisticated transactions from this requirement.
2. Application timing: A complete application must be submitted a minimum of 12 months before the start of the first fiscal year covered by the agreement.

How to apply:

Interested taxpayers should contact their account manager for detailed guidance. Alternatively, inquiries can be directed to APA-gma@zatca.gov.sa.

How can Deloitte support your business? 

At Deloitte, we offer comprehensive support throughout the APA process, offering expertise in the following areas: 

• Initial assessment: Determining eligibility for the APA process. 
• Documentation preparation: Assisting in preparing all required documentation.
• Application submission: Guiding through the application process and ensuring timely submission.
• Pre-filing consultation: Arranging and facilitating pre-filing consultations with ZATCA.
• Ongoing compliance and monitoring: Providing support to ensure compliance and assist with monitoring and reporting.
• Dispute resolution: Assisting with resolving any disputes during the APA process.
• Training and workshops: Offering training sessions to enhance your team’s understanding of the APA process.

For personalized assistance and to learn more about how Deloitte can support your APA application, please contact us.