A Saudi taxable person that carries out transactions with related parties must comply with the Transfer Pricing Bylaws. Under Article 14 of those Bylaws, when must the Controlled Transactions Disclosure Form (CTDF) generally be submitted to ZATCA?
- Only on request, whenever ZATCA opens a formal transfer pricing audit of the taxpayer
- Once every three years, as part of a rolling transfer pricing documentation review cycle
- Together with the taxpayer's annual income tax or Zakat declaration, within 120 days of the end of the relevant fiscal year
- At the time each individual controlled transaction is invoiced, rather than on any annual cycle
Why C? And why not the others?
Correct answer: C. Together with the taxpayer's annual income tax or Zakat declaration, within 120 days of the end of the relevant fiscal year
Article 14 of the Transfer Pricing Bylaws builds the CTDF into the regular annual filing cycle: a taxpayer with related-party transactions submits the form together with its annual income tax or Zakat declaration, and both are due within 120 days of the end of the relevant fiscal year. The option limiting the filing to when ZATCA opens an audit is wrong because the CTDF is a proactive, standing annual disclosure obligation, not a reactive submission triggered only by an authority-initiated inquiry. The option describing a three-year rolling review cycle is wrong because no such multi-year cycle governs the CTDF; the obligation recurs every single fiscal year in which the taxpayer has controlled transactions, not once every three years. The option tying submission to each individual invoice is wrong because the CTDF aggregates and discloses the taxpayer's controlled transactions for the whole fiscal year in one periodic filing, rather than being generated transaction-by-transaction as invoices are issued.
Source: Saudi Transfer Pricing Bylaws, Article 14 (Controlled Transactions Disclosure Form)