Transfer Pricing Documentation services comprise the preparation of 3-tier documentation, i.e. Local File, Master File and Country-by-Country Report (‘CbCR’). We support consultants/ advisors in the preparation of documentation.
Preparation of Master
Preparation of Master file in accordance with the KSA TP bylaws and OECD TP Guidelines, taking into consideration the local regulations. A Masterfile will consist of the following sections:
- Organizational structure;
- Description of Multinational Enterprise Group’s business;
- Information on the Multinational Enterprise Group’s Intangibles;
- Information on the Multinational Enterprise Group’s intercompany financial activities; and
- Information on the Multinational Enterprise Group’s financial and tax positions
Local file preparation
Preparation of a Local File in accordance with the KSA Transfer Pricing By-Laws issued by the ZATCA. A Local File generally includes:
- Management structure of the Taxpayer/Zakatpayer;
- Details of related party and controlled transactions;
- Industry overview;
- Arm’s length analysis for all the transactions;
- Financial data of the Company; and
- Financial data of the comparable companies, etc.
Preparation of Country-by-Country Report
Preparation of Country-by-Country Report in accordance with the KSA TP bylaws and OECD TP Guidelines.
- Gather financial and operational data for the multinational enterprise, including entity information and global allocation of income, taxes, and business activities.
- Compile and format the CbC Report ensuring accuracy and compliance with both KSA and OECD standards.
- File the report with ZATCA by the deadline and address any additional requests or queries.
