This document outlines a 4 step methodology for implementing transfer pricing bylaws in Saudi Arabia. The steps include: 1) critical assessment of related parties defined under transfer pricing bylaws. 2) use of an appropriate transfer pricing method to determine the arm's length value of controlled transactions. 3) impact assessment on the tax base of the organization. 4) determining the impact of transfer pricing bylaws on the policies and processes of the organization. The transfer pricing bylaws in Saudi Arabia apply to all taxpayers under income tax law, including mixed entities owned partly by non-Saudis.

1. Group Overview
Industry Analysis
Functional Analysis
Economic Analysis
Organizational Structure
MNE’s Business
Intangibles
MNE’s Financial and Tax Position
MNE’s Financing
Applicability
Transfer Pricing Bylaws are applicable to all persons considered taxpayers pursuant to the Income
Tax Law (including mixed-ownership entities the income of which is subject to corporate income tax
to the extent attributed to shares owned by non-Saudis and those treated by Saudis).
Step 01
Our methodology for Transfer Pricing Implementation
Critical assessment of related parties defined
under Transfer Pricing Bylaws
Step 03
Impact Assessment on the tax base of the
organization
Step 02
Use of appropriate Transfer Pricing method
for determining arm’s length value of
controlled transactions
Step 04
Determining the impact of Transfer Pricing
Bylaws on the policies and processes
of the organization
Transfer Pricing Documentations
Local File Structure: Master File Structure:
M. AMMAD ZAFAR
Assist Manager Business Development
+966 53 770 0515
mazafar@insightss.co www.insightss.co
Transfer Pricing