The Controlled Transaction Disclosure Form (CTDF) is the centrepiece of transfer pricing compliance in Saudi Arabia. Every taxpayer that transacts with related parties must file it with ZATCA as part of the annual return, within 120 days of the financial year-end, which means 30 April for a business on the calendar year. Unlike the Local File and Master File, the CTDF carries no size threshold.
Key takeaways
- The CTDF discloses every controlled (related-party) transaction and the transfer pricing method applied to it. There is no minimum threshold, so it reaches all taxable persons with related-party dealings.
- It is filed with the tax return within 120 days of the financial year-end, meaning 30 April for calendar-year taxpayers.
- A licensed local auditor must certify the disclosure through an affidavit in Arabic, confirming that the transfer pricing policy and the figures are accurate and consistent.
- The CTDF is ZATCA's first audit touchpoint. It drives risk assessment and case selection, so any inconsistency with the Local File invites scrutiny.
- Saudi transfer pricing compliance also covers the Local File, the Master File, General Documentation and, for large groups, a Country-by-Country (CbCR) notification.
- Corporate taxpayers, 100% zakat payers and mixed-ownership entities are all in scope; only natural persons and small taxpayers below the size thresholds escape the Local and Master File, not the CTDF.
What is the CTDF and who must file it?
A "controlled transaction" is simply a transaction between related parties, such as two companies in the same group, and the CTDF is where you tell ZATCA about them. It is required under Article 17 of the KSA Transfer Pricing Bylaws and applies to every taxable person that has entered into any related-party transaction during the year, whether the counterparty sits inside the Kingdom or abroad. There is deliberately no monetary floor: a single intercompany invoice is enough to bring you into scope.
The form itself summarises each controlled transaction and the transfer pricing method used to price it, and it declares whether you also fall within the Local File, Master File and CbCR obligations. In other words, the CTDF is both a disclosure and a self-assessment of the rest of your documentation duties. Because it applies to corporate taxpayers, 100% zakat payers and mixed entities alike, most active groups operating in Saudi Arabia will need to file one.
The 120-day deadline and the auditor affidavit
The CTDF is not a standalone filing. It goes in with the corporate tax or zakat return, and the deadline is the same: 120 days after the end of the financial year. For the large population of calendar-year taxpayers, that lands on 30 April. Missing the return deadline therefore means missing the CTDF deadline, with the penalty consequences that follow from late filing.
What sets the Saudi regime apart is the affidavit. A licensed local auditor must certify the disclosure in Arabic, attesting that the transfer pricing policy and the disclosed figures are accurate and internally consistent. That third-party sign-off raises the stakes: the numbers in the CTDF have to reconcile with the audited accounts and with the Local File, or the auditor cannot comfortably certify them. Building in time for that certification before 30 April is essential rather than optional.
Why the CTDF matters: the first audit touchpoint
The CTDF is the first thing ZATCA reads, so it frames how the authority sees your entire transfer pricing position before it opens a single supporting file.
ZATCA uses the CTDF as its first-level filter for assessment and case selection. Several things commonly go wrong at this stage. Choosing the wrong "most appropriate" method undermines everything built on top of it. Disclosures that do not line up with the Local File flag an inconsistency the authority is trained to spot. Skipping a pre-filing true-up, the year-end adjustment that brings actual results back to the arm's length target, leaves an exposed gap. And an incomplete or missing auditor affidavit stalls the filing altogether. A downward adjustment that reduces Saudi taxable income tends to draw particular attention, so the rationale needs to be documented before, not after, submission. In practice, SBC reconciles the CTDF to the Local File and the audited accounts before the auditor signs, because the affidavit is only as strong as the numbers behind it.
The wider compliance picture
The CTDF sits inside a broader set of obligations. Corporate taxpayers (100% non-GCC owned), 100% zakat payers (100% GCC owned) and mixed entities are all covered. Natural persons, small taxpayers with controlled transactions under SAR 6 million and small 100% zakat payers under SAR 48 million are exempt from the Local and Master File, but the disclosure form and General Documentation still apply. The table below shows how the pieces fit together.
| Obligation | Who it applies to | Filed or maintained? |
|---|---|---|
| CTDF + auditor affidavit | All taxpayers with related-party transactions | Filed with the return, within 120 days |
| Local File | Taxpayers/mixed entities above SAR 6m; zakat payers above the phased thresholds | Maintained; produced within 30 days of a ZATCA request |
| Master File | As for the Local File | Maintained; produced within 30 days |
| General Documentation | Taxpayers exempt from the Local and Master File | Maintained; produced within 30 days |
| CbCR notification | MNE groups with consolidated revenue above SAR 3.2 billion | Filed on the AEOI portal |
If your group crosses the Local File thresholds, the disclosure form is only the visible tip of the work; the transfer pricing documentation behind it has to stand on its own. For cross-border groups, the international tax treatment of each flow feeds directly into what the CTDF discloses.
Frequently asked questions
What is the Controlled Transaction Disclosure Form in Saudi Arabia?
The CTDF is a mandatory ZATCA form on which a taxpayer discloses all of its related-party (controlled) transactions and the transfer pricing method applied to each. It is required under Article 17 of the KSA Transfer Pricing Bylaws, applies with no minimum threshold, and is filed together with the annual tax or zakat return.
When is the CTDF due?
The CTDF is filed with the tax return within 120 days of the end of the financial year. For taxpayers on the calendar year, that means 30 April. Because the form and the return share the deadline, a late return is also a late disclosure form.
Does the CTDF have a minimum threshold?
No. Unlike the Local File and Master File, which only bite above set thresholds, the CTDF applies to all taxable persons that entered into any transaction with a related party during the year. A single intercompany transaction is enough to trigger the filing obligation.
Do I need an auditor affidavit for the CTDF?
Yes. A licensed local auditor must certify the disclosure through an affidavit in Arabic, confirming that the transfer pricing policy and the disclosed figures are accurate and consistent. Leaving enough time for that certification before the 30 April deadline is part of a sound compliance plan.
How SBC Tax Consulting can help
SBC helps Saudi taxpayers file accurate, defensible CTDFs that reconcile with their transfer pricing documentation and audited accounts. We advise on method selection, benchmarking alignment and pre-filing true-ups so the disclosure holds up as ZATCA's first audit filter, and we support the auditor affidavit process and any ZATCA audit or dispute that follows. To prepare for the next 30 April deadline, contact our team.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.