Tax dynamics in GCC countries have significantly changed in the
last decade due to economic challenges. The topic of TP has gained significant
momentum over the past few years, especially after the GCC countries in the
region (except Kuwait) have joined the Base Erosion and Profit Shifting (BEPS)
framework.
|
Saudi Arabia CbCR since 2018
|
Qatar CbCR since 2018
|
|
Oman
CbCR since 2020
|
Bahrain
CbCR
since 2021 Regulations
|
|
Kuwait
CbCR –
NA
|
UAE
CbCR
since 2019
TP
regulations from June 1, 2023
|
| Country | Applicability | Permissible Pricing Methods | Documentation | Advanced ruling or Pricing Agreements | Penalties for non-compliance |
|---|---|---|---|---|---|
| KSA | All juridical persons, including mixed companies | As per the OECD Guidelines | The controlled transaction disclosure form General documentation Maintain - Local and Master file | Permissible | As per IT Law |
| Qatar | Transactions between a Qatar resident entity and an unrelated foreign entity if in a preferential tax regime or residing in a cooperativenon-cooperativecountry. | Preferred CUP method Alternatively, as per the OECD Guidelines | TP declaration be submitted along with the annual income tax return Submission of Local and Master file | Permissible | As per IT Law |
| Oman | Measures of Related party Transaction through IT Law, no specific TP Regulation | No specific mention.The OECD Guidelines Recommended | No specific Regulations Recommend maintaining Documents to be made available on request | Permissible | Imposed |
| Bahrain | No TP Regulations or measures to monitor related party transactions | NA, as no TP Regime | NA, as no TP Regime | NA, as no TP Regime | NA, as no TP Regime |
| Kuwait | Transactions between domestic and a foreign entity | Covered Transactions to be as Arm’s Length Price | Declared costs and expenses from the head office or related parties must be fully documented for the tax inspection. Except in cases where a tax the treaty applies, deemed | NA | NA |
* Indicated in Public Consultation Document
