Transfer Pricing
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Transfer Pricing

Effective transfer pricing management is essential not only for regulatory compliance but also for minimizing tax risk, avoiding disputes with tax authorities, and ensuring that multinational groups maintain transparent and defensible pricing policies.

Our transfer pricing services are designed to help businesses operating in Saudi Arabia establish compliant, well-documented, and defensible intercompany pricing frameworks. We assist clients throughout the entire transfer pricing lifecycle—from planning and documentation to compliance and dispute support.

Transfer Pricing Advisory

We assist organizations in designing and implementing transfer pricing policies aligned with the arm’s length principle. Our advisory services evaluate intercompany transactions, functional profiles, and risk allocation to establish defensible pricing structures.

Transfer Pricing Documentation

Preparation of comprehensive transfer pricing documentation in accordance with regulations issued by the Zakat, Tax and Customs Authority and aligned with the framework recommended by the Organisation for Economic Co-operation and Development, including:

Master File

Local File

Country-by-Country Reporting (CbCR) notifications and filings

Benchmarking and Economic Analysis

We conduct detailed benchmarking studies and economic analyses to determine arm’s length pricing for related-party transactions such as management fees, service arrangements, royalties, financing transactions, and intercompany supply of goods.

Intercompany Agreements

Drafting and review of intercompany agreements to ensure that legal documentation aligns with the economic substance of transactions and transfer pricing policies.

Review of existing intercompany arrangements to identify compliance gaps, potential tax exposure, and documentation deficiencies, followed by practical recommendations to strengthen compliance.

Transfer Pricing Compliance and Disclosure

Assistance with preparation and submission of transfer pricing disclosure forms, ensuring that all related-party transactions are accurately reported in line with Saudi tax regulations.

Our transfer pricing services include the following services, among many others:

  • • Transfer Pricing Advisory
  • • Transfer Pricing Documentation
  • • Benchmarking and Economic Analysis
  • • Intercompany Agreements
  • • Transfer Pricing Compliance and Disclosure

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