Can taxpayers or ZATCA conduct a comparability analysis based on data not accessible to the public?

As per Article 13 of the Transfer Pricing Bylaws, comparability analysis must be arranged by applying data that is accessible or can be made accessible to the public. Consequently, the taxpayer cannot use information that cannot be made accessible to ZATCA and vice versa.

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Can taxpayers or ZATCA conduct a comparability analysis based on data not accessible to the public?