A multinational group has its ultimate parent entity resident in Saudi Arabia. Under Saudi Arabia's Country-by-Country Reporting (CbCR) requirements, which of the following correctly states when the group becomes subject to CbCR notification and reporting obligations with ZATCA?
- Whenever the group has a presence in more than one GCC country, regardless of the size of its consolidated revenue
- When the group's total consolidated revenue for the preceding fiscal year exceeds SAR 3.2 billion, in which case the CbCR report is generally due within 12 months of that fiscal year-end
- Whenever any single constituent entity of the group individually reports revenue above SAR 375,000 in Saudi Arabia, the same figure used for VAT registration
- Only if the group's ultimate parent entity is a non-resident company with a Saudi branch; Saudi-parented groups are outside the CbCR regime entirely
Why B? And why not the others?
Correct answer: B. When the group's total consolidated revenue for the preceding fiscal year exceeds SAR 3.2 billion, in which case the CbCR report is generally due within 12 months of that fiscal year-end
CbCR notification and reporting obligations, aligned with OECD BEPS Action 13, are triggered by the size of the multinational group's consolidated revenue in the preceding fiscal year: once that consolidated figure exceeds SAR 3.2 billion, the constituent entity (or the ultimate parent itself, if Saudi-resident) must notify ZATCA and the CbCR report is generally due within 12 months of the relevant fiscal year-end. The option tying the obligation to having a presence in more than one GCC country is wrong because geographic footprint within the GCC is not the trigger; the rule is a single consolidated-revenue threshold that applies regardless of how many GCC states the group operates in. The option borrowing the SAR 375,000 VAT mandatory registration figure is wrong because that threshold belongs to an entirely different regime, VAT registration for a single taxable person's domestic supplies, and has no bearing on a multinational group's CbCR obligations. The option restricting CbCR to groups with non-resident parents and a Saudi branch is wrong because a Saudi-resident ultimate parent of a large enough group is itself squarely within scope, and is in fact the more typical case where the Saudi entity files the report directly rather than relying on a foreign parent's filing.
Source: ZATCA Country-by-Country Reporting requirements (OECD BEPS Action 13); ZATCA CbCR e-service guidance