What additional obligations are there under the Transfer Pricing Bylaws?

A number of obligations deriving from the Transfer Pricing Bylaws, the most significant of which are:

Submit the Transactions Disclosure Form along with the tax return. The Disclosure Form must be in an electronic form that is part of the tax return.
Sustain a Master File containing – generally- information on the global business of the MNE group to which the taxpayer resides. Taxpayers who carry out transactions, the arm’s length value of which does not exceed SAR 6 million in a 12-month period are exempt from this commitment.
Secure Local File including – generally - information on all the taxpayer’s transactions. Taxpayers who carry out transactions, the arm’s length value of which does not exceed SAR 6 million in a 12-month period, are exempt from this commitment.
Country-by-Country (CbC) Report – where consolidated group revenue of the MNE group exceeds SAR 3.2 billion, for all persons belonging to the group and who, according to the Bylaws are considered to be entities committed to submitting the CbC Report, must submit the CbC Report.

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