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Are persons subject to Zakat in accordance with the Implementing Regulations of Zakat Collection subject to the Transfer Pricing Bylaws?

Persons subject to Zakat (i.e., 100% Zakat payers) are not subject to the Transfer Pricing Bylaws. However, taxpayers under the Income Tax Law and its Implementing Regulations are subject to Transfer Pricing Bylaws which includes 100% taxable persons or mixed companies (subject to Zakat and tax), except for Article 18 of Transfer Pricing Bylaws which is applicable to all persons, including those subject to Zakat by 100%. This Article states that a multinational enterprises group whose consolidated annual revenues exceed SAR 3.2 billion shall submit a Country-by-Country (CbC) report in accordance with all provisions and details provided in the same Article.​​