Saudi Arabia has introduced targeted amendments to the VAT Implementing Regulations that affect e-commerce platforms and electronic marketplaces operating in the Kingdom. The changes provide greater clarity on marketplace responsibilities, define the scope of supply facilitation, and introduce distinct effective dates that businesses should consider when reviewing their VAT positions.
Recent amendments issued by the Zakat, Tax and Customs Authority (ZATCA) refine the VAT treatment of electronic marketplaces in Saudi Arabia, particularly in relation to when a platform may be regarded as facilitating a supply and therefore responsible for accounting for VAT.
The amendments address different marketplace scenarios, including supplies involving non-resident suppliers, resident suppliers that are not VAT registered, and activities that fall outside the scope of supply facilitation. They also introduce phased effective dates, requiring businesses to assess both immediate and upcoming compliance implications.
Deloitte has developed this article to help businesses understand the practical impact of the amendments, identify areas of potential exposure, and evaluate whether existing operating models, contractual arrangements, and VAT processes remain aligned with the updated regulatory framework.