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What are the fiscal years to which the requirements of sustaining and filing documentation apply under the Transfer Pricing Bylaws (Master file, Local File, CbC Report)?  Are there any exemptions?


Persons concerned with such Bylaws should satisfy the requirements related to the transfer pricing (such as Main File, Local File, and the CbC Report, without limiting). Bylaws will be effective from the date of their coming into force. The Transfer Pricing Bylaws are relevant to all taxpayers whose deadline for filing the tax return ‎happens on or after January 1. Implementation will be without prejudice to GAZT's rights following the Income Tax Law ‎to request information, documents, or conducting an audit related to the years preceding the ‎effective date of the Transfer Pricing Bylaws. It is worth noticing that under Administrative Decree No. 19008 dated 24 Rajab 1440H, April 30, 2019, is the deadline for filing Transfer Pricing Forms for taxpayers subject to such Bylaws, are legally obligated to file their tax returns in the period from January 1, 2019, to 30/4/2019. If GAZT inquires any information or documents that relate to Transfer Pricing ‎Bylaws, such as the Master or Local files, the taxpayer must submit the required documents ‎to GAZT within the time limit indicated in the request and in all cases this will not be less than ‎‎30 days from the date of the request. GAZT may request the Master File and/or the Local File ‎at any time after the date of the tax return filing deadline. During the 2019 calendar year, all ‎taxpayers will be granted an extension of 60 days. Therefore, taxpayers will have a minimum of 210 days (120 days + 30 days (minimum) ‎from the request+ (60 days extension) at minimum to develop and file the Local File and Main File for GAZT requests during 2019.