Transfer Pricing

In today’s evolving tax environment, transfer pricing (TP) has become a strategic priority for businesses operating in the Middle East. With increasing scrutiny from ZATCA and other GCC tax authorities, aligning intercompany transactions with global and local requirements is essential to manage risk, ensure compliance, and optimize tax efficiency.

In Saudi Arabia, TP rules apply to both tax and Zakat payers. Entities are required to maintain comprehensive TP documentation, submit the annual disclosure form and affidavit, and ensure the application of appropriate TP methodologies in line with ZATCA guidelines. Importantly, domestic related-party transactions are also subject to TP rules.

At KPMG, we help businesses design, document, and defend robust transfer pricing policies that meet regulatory expectations and support commercial objectives.

We provide end-to-end support across the entire transfer pricing lifecycle.

We help you establish transfer pricing structures that reflect your business reality and value chain.

• Design and implementation of transfer pricing models
• Functions, assets, and risk analysis (FAR)
• Profit allocation and value chain assessments
• Intercompany pricing for goods, services, and intangibles
• IP structuring and royalty benchmarking
• Advance pricing agreements (APAs)

We ensure your transfer pricing documentation meets local TP regulations and OECD guidelines.

• Local file (LF) and master file (MF) preparation
• Benchmarking studies using regional comparables
• TP disclosure forms and ZATCA compliance reviews
• Annual documentation updates and reviews

Our team provides practical support in managing tax authority reviews and transfer pricing audits.

• Audit defense and response strategy
• Assistance during ZATCA TP audits

We assist finance and tax teams in embedding TP practices into day-to-day operations.

• TP automation and analytics tools
• Integration with ERP and reporting systems
• Periodic monitoring and adjustment mechanisms
• Assurance testing of TP policies