Saudi Transfer Pricing Compliance and the 30 April Disclosure Form

If your UAE group has a subsidiary, branch, or investment in Saudi Arabia, one Saudi filing deserves your attention more than most: the Controlled Transaction Disclosure Form, usually shortened to CTDF. It is the first thing the Zakat, Tax and Customs Authority (ZATCA) reads about your related-party dealings, it carries no size threshold, and it comes with a certification requirement that surprises many finance teams the first time they meet it.

For a UAE headquarters, the CTDF is easy to underestimate. It sits inside the Saudi return, not the UAE return, and it is often left to the local Saudi finance team or a local accountant. That works right up until the numbers on the CTDF do not match the group transfer pricing story, or the Arabic auditor affidavit cannot be signed in time. This guide explains what the CTDF is, who must file it, how it fits with the wider Saudi documentation obligations, and, most importantly, what a UAE-based group should do to stay on top of it. It also compares the Saudi disclosure mindset with the UAE approach, so regional finance teams can run both without confusing the two.

What is the Saudi Controlled Transaction Disclosure Form (CTDF)?

A "controlled transaction" is simply a transaction between related parties, for example two companies in the same group, or a Saudi entity dealing with its UAE parent. The CTDF is the form on which a taxpayer tells ZATCA about those transactions and the transfer pricing method used to price each of them.

In practical terms the CTDF does two jobs at once. It is a disclosure of every controlled transaction for the year, and it is a self-assessment of the taxpayer's other transfer pricing obligations, because it also declares whether the taxpayer falls within the Local File, Master File and Country-by-Country reporting requirements. It is required under the Saudi transfer pricing framework administered by ZATCA and sits alongside the wider Saudi income tax implementing regulations.

The transfer pricing framework in Saudi Arabia follows the internationally recognised arm's length principle, the same principle the OECD Transfer Pricing Guidelines 2022 describe as the global consensus for pricing cross-border transactions between associated enterprises. So the CTDF is not a Saudi-only invention. It is Saudi Arabia's way of operationalising a global standard, which is helpful for UAE groups that already think in OECD terms for their home-country compliance.

What changed in practical importance for 2026?

The CTDF itself is not new. What has changed is the environment around it. Related-party scrutiny across the GCC has intensified, transfer pricing documentation is now a live audit issue rather than a future policy, and tax authorities in the region increasingly compare what a group discloses in one jurisdiction against what it discloses in another.

For UAE groups, this matters because UAE Corporate Tax is now in force, and the UAE has its own related-party disclosures embedded in the Corporate Tax Return. That means a UAE parent and its Saudi subsidiary are each disclosing the same intercompany flows to two different authorities. If the Saudi CTDF describes an intercompany service one way and the UAE disclosure describes it another way, the inconsistency is now visible in a way it was not a few years ago.

The practical takeaway is not that any Saudi rule has been rewritten. It is that the cost of a sloppy CTDF has risen, because the disclosure no longer sits in isolation. It sits next to a growing set of regional filings that can be cross-read.

Who must file the CTDF, and is there a threshold?

This is where the CTDF differs sharply from most documentation obligations, and where UAE finance teams most often get caught out.

The CTDF applies to any taxpayer that has entered into a controlled transaction during the year, with deliberately no monetary threshold. A single intercompany invoice is enough to bring a Saudi entity into scope. There is no minimum value below which a Saudi entity can skip the form.

In practice this reaches a broad population, including:

• Corporate income tax payers, typically Saudi entities with non-GCC ownership.
• Zakat payers, typically wholly Saudi or GCC-owned entities.
• Mixed-ownership entities that pay a blend of both.

Only a limited set of taxpayers sit outside parts of the wider documentation regime, and even they generally still have the disclosure obligation. The important point for a UAE group is that having "only a small intercompany charge" into Saudi Arabia does not remove the CTDF requirement. If the Saudi entity transacted with a related party at all, the form is in play.

Quick takeaway: treat the CTDF as mandatory for any Saudi entity in your group that has any related-party transaction, however small.

How does the CTDF relate to the Saudi income tax or zakat return?

The CTDF is not a standalone filing you submit separately. It goes in with the Saudi corporate income tax or zakat return, and it shares that return's deadline. This is a structural point worth internalising: if the return is late, the CTDF is late, and the penalty consequences of a late return follow automatically.

That linkage has a governance implication for UAE groups. The team or adviser responsible for the Saudi return is, in effect, also responsible for the CTDF, whether or not they think of it that way. Where a UAE HQ owns the group transfer pricing policy but the Saudi return is filed locally, the CTDF is the exact point where those two responsibilities have to meet.

What is the 120-day deadline, and what does it mean for calendar-year taxpayers?

The Saudi return, and therefore the CTDF, is due within 120 days of the end of the financial year. For the large population of taxpayers on the calendar year, that lands on 30 April.

For a UAE group, the practical consequence is timing pressure that can clash with your own cycle. Many UAE parents are still closing group accounts and preparing their own filings in the same window. The Saudi 120-day clock does not wait for the group process to finish. A UAE finance team that treats the Saudi filing as something to handle "after the group close" can find itself out of time.

The following table sets out how the deadline typically falls for a calendar-year Saudi entity. Where a Saudi entity uses a non-calendar financial year, the 120-day rule applies to that year-end instead, so the date shifts accordingly.

Dates other than the calendar-year example above are indicative and depend on the exact year-end. Confirm the precise due date for each Saudi entity rather than assuming a single group deadline.

Why is the Arabic auditor affidavit such an important feature?

The feature that most distinguishes the Saudi regime from the UAE approach is the affidavit. A licensed local auditor must certify the CTDF disclosure through an affidavit in Arabic, attesting that the transfer pricing policy and the disclosed figures are accurate and internally consistent.

This is not a formality. The auditor cannot comfortably certify figures that do not reconcile to the audited accounts and to the underlying transfer pricing documentation. So the affidavit effectively imports a third-party consistency check into the filing, before it ever reaches ZATCA.

For a UAE group, the affidavit has two direct consequences. First, it lengthens the timeline, because the auditor needs the numbers, the method, and the supporting analysis in enough time to review and sign before the deadline. Second, it raises the bar on internal consistency, because the CTDF, the accounts, and the transfer pricing file all have to tell the same story. A UAE HQ that finalises its intercompany positions late leaves the Saudi auditor with too little time, which is one of the most common causes of a rushed or weak Saudi filing.

Quick takeaway: build the auditor affidavit into your Saudi timeline as a hard dependency, not a final rubber stamp.

Why does the CTDF matter for ZATCA risk assessment?

The CTDF is the first document ZATCA reads on a taxpayer's transfer pricing position. That makes it the primary input into risk assessment and case selection. Several issues commonly surface at this stage.

Choosing the wrong "most appropriate" transfer pricing method undermines everything built on top of it, because the disclosed method frames how the authority reads the rest of the file. Disclosures that do not line up with the Local File create an inconsistency that reviewers are trained to spot. A downward adjustment that reduces Saudi taxable income tends to attract particular attention, so the rationale should be documented before submission, not after. And an incomplete or missing auditor affidavit can stall the filing entirely.

Because the CTDF frames the authority's first impression, it is worth getting right even where the underlying pricing is sound. A defensible transfer price described inconsistently on the CTDF can still trigger a review.

How does the CTDF interact with the Local File, Master File, General Documentation and CbCR?

The CTDF sits at the top of a broader set of Saudi obligations. Understanding how they fit together helps a UAE group avoid both over-compliance and gaps. The table below sets out the relationship at a high level.

The Local File and Master File thresholds are set out in more detail in our note on KSA transfer pricing Local File and Master File thresholds. Where a Saudi entity falls below those thresholds, General Documentation usually still applies, so being under the Local File threshold does not mean no documentation at all. The CbCR notification is a separate, group-level obligation driven by consolidated revenue, and it is relevant where a UAE-parented group is large enough to be within the OECD's Action 13 country-by-country reporting framework.

The key relationship to remember is that the CTDF is the visible tip. The Local File and Master File are the evidence underneath it. If the CTDF discloses a method and a margin, the documentation has to stand behind that disclosure if ZATCA asks. For a fuller picture of the Saudi disclosure and affidavit process, our Saudi CTDF article covers the mechanics, and the penalty exposure is set out in KSA transfer pricing penalties for non-compliance.

What should UAE-based groups with Saudi entities collect before filing?

The single most useful thing a UAE HQ can do is treat the CTDF as a data exercise that starts well before the deadline. A strong Saudi filing depends on the same transaction facts the group already needs for its UAE compliance, extended to cover the Saudi return and the affidavit.

Before the Saudi filing, a UAE group should be able to pull together:

• A complete list of every related-party transaction the Saudi entity had during the year, with the counterparty and its location.
• The transfer pricing method applied to each transaction, and why it is the most appropriate method.
• The value of each transaction, reconciled to the Saudi entity's audited accounts.
• The intercompany agreements that govern each flow, consistent with how the parties actually behaved.
• Any year-end true-up or adjustment, with its rationale documented in advance.
• The group Master File, where the group is large enough to need one, and the Saudi Local File where the thresholds are met.
• Confirmation of who at the Saudi entity and who at the UAE HQ signs off before the auditor certifies.

Getting the intercompany agreements right is central, because the contract, the invoices, and the transfer pricing analysis should describe the same arrangement. Our note on intercompany agreements in the UAE sets out that discipline, and it applies just as much to a Saudi flow as a UAE one.

How should governance work between UAE HQ and Saudi finance teams?

The CTDF is where a common regional weakness shows up: the group transfer pricing policy lives with UAE tax, but the Saudi return and affidavit are handled locally, and the two only meet at the last minute.

A workable governance model closes that gap in advance:

1. The UAE HQ owns the group transfer pricing method and confirms it in time for the Saudi filing, not after.
2. The Saudi finance team owns the return, the CTDF entries, and the relationship with the local auditor.
3. Both agree, before year-end, how any downward adjustment or true-up will be handled and documented.
4. A shared transaction list is used, so the CTDF, the Saudi accounts, and the group documentation reconcile to the same figures.
5. The auditor is engaged early enough to review and sign the affidavit before the deadline.

This is the same operational logic that keeps a UAE transfer pricing policy consistent from policy through to invoice. The method has to be the method actually applied, and the disclosure has to match the books.

How does the Saudi CTDF mindset differ from UAE transfer pricing disclosure?

For a regional finance team running both, the two systems share a foundation but differ in important, practical ways. Both apply the arm's length principle, both expect Local File and Master File documentation for larger taxpayers, and both draw on the OECD framework. The differences are in the mechanics.

The table below sets out the contrast. The UAE points are drawn from Federal Decree-Law No. 47 of 2022, Ministerial Decision No. 97 of 2023, and the guidance published on the FTA Corporate Tax pages.

The most important practical difference is the disclosure trigger. In the UAE, the related-party disclosure schedules are only completed once specific thresholds are crossed, and the UAE Transfer Pricing Disclosure Form guide explains how those thresholds work. In Saudi Arabia, the CTDF applies to any related-party transaction at all. A UAE finance team used to the threshold model can wrongly assume a small Saudi charge is below a filing line, when Saudi Arabia has no such line for the CTDF.

The second key difference is the affidavit. The UAE has no equivalent third-party certification of the disclosure, so a UAE team meeting the affidavit for the first time needs to plan for auditor involvement it does not use at home. The UAE transfer pricing compliance guide sets out the UAE model, and it is worth reading alongside the Saudi rules precisely because the mechanics diverge.

A shared point, though, is that in both jurisdictions the arm's length rule applies regardless of size. UAE thresholds govern what must be disclosed and documented, not whether the arm's length principle applies. That distinction is the same one that runs through who is covered by UAE transfer pricing rules and how to identify Related Parties.

What records should be retained, and how ready should you be for audit?

Audit readiness for the CTDF rests on being able to reproduce, on request, the analysis behind every disclosed transaction. In practice that means retaining, for each Saudi entity:

• Intercompany agreements, invoices, and payment records for each related-party flow.
• The benchmarking or comparability analysis supporting the pricing.
• The Local File and Master File where the thresholds are met, and General Documentation where they are not.
• The auditor affidavit and the reconciliation between the CTDF, the accounts, and the documentation.
• The rationale for any adjustment or true-up made during the year.

Retention periods and production windows are set by the Saudi framework, so confirm the current requirements for each entity rather than assuming a single group standard. The broader ZATCA guidance and manuals are published on the ZATCA guidelines page, and the underlying income tax regulations are available through the ZATCA income tax regulations page. Because these details can be updated, verify the current position for the relevant filing year.

What are the common mistakes UAE groups make with the CTDF?

• Assuming a threshold exists. Treating a small Saudi intercompany charge as too minor to disclose. The CTDF has no threshold.
• Leaving the affidavit too late. Finalising intercompany positions so close to the deadline that the auditor cannot review and sign in time.
• Inconsistent disclosures. The CTDF describing a transaction one way and the group documentation or the UAE disclosure describing it another way.
• Booking a downward adjustment without a documented rationale. Reducing Saudi taxable income through a true-up and only reaching for the justification after filing.
• Choosing the wrong method. Disclosing a method that does not fit the transaction, which frames the whole file badly for ZATCA.
• Siloed responsibility. UAE HQ owning the policy while the Saudi team files the CTDF, with neither reconciling to a shared transaction list.
• Ignoring General Documentation. Assuming that being below the Local File threshold means no documentation is needed.

Practical recommendations for UAE groups operating in Saudi Arabia

1. Map every related-party flow into and out of each Saudi entity, and confirm each one will be captured on the CTDF.
2. Reconcile the CTDF figures to the Saudi audited accounts and to the group transfer pricing documentation before the auditor is asked to certify.
3. Engage the Saudi auditor early, and treat the affidavit as a scheduled dependency, not a final formality.
4. Confirm the method applied to each transaction is the most appropriate one, and document why.
5. Decide and document the rationale for any true-up or downward adjustment before it is booked.
6. Keep the Saudi disclosure consistent with the UAE disclosure of the same intercompany flow.
7. Assign clear ownership across UAE HQ and the Saudi team, working from one shared transaction list.
8. Diarise the 120-day deadline for each Saudi entity separately, based on its actual year-end.

Because the CTDF, the accounts, and the documentation all have to align, this is also the point where UAE-side support is useful. SBC's Transfer Pricing and Corporate Tax practices help groups keep the Saudi and UAE positions consistent, and the wider range of services and the insights hub cover related GCC compliance questions. Management fee flows into Saudi entities raise their own benefit-test and pricing questions, covered in our note on management fees in the UAE, and payments to owners, directors, and officers raise the separate issues set out in Connected Persons under UAE Corporate Tax. Where the group is large enough, the UAE Master File question should be resolved in parallel with the Saudi documentation, since the same group facts feed both.

Frequently asked questions

Is there a minimum value below which a Saudi entity can skip the CTDF?

No. The CTDF applies to any taxpayer that had a controlled transaction during the year, with no monetary threshold. A single intercompany invoice is enough to bring the entity into scope.

Is the CTDF filed separately from the Saudi return?

No. It is filed together with the Saudi income tax or zakat return and shares that return's deadline, which is 120 days after the financial year-end. For calendar-year taxpayers that is 30 April.

Do we really need a local auditor affidavit?

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 deadline is part of a sound plan.

Our Saudi entity is small. Does it still need documentation?

Possibly, in the form of General Documentation even where the Local File and Master File thresholds are not met. Being below the Local File threshold does not automatically mean no documentation obligation, and the CTDF still applies. Confirm the current position for the relevant year.

How is the Saudi CTDF different from the UAE disclosure form?

The biggest differences are the trigger, the deadline, and the affidavit. Saudi Arabia has no CTDF threshold and a 120-day deadline with an Arabic auditor affidavit. The UAE uses value thresholds, a nine-month deadline, and no equivalent affidavit. Both apply the arm's length principle regardless of size.

Who should own the CTDF in a UAE-headquartered group?

Ownership is shared in practice. The UAE HQ typically owns the group transfer pricing method, and the Saudi finance team owns the return, the CTDF entries, and the relationship with the local auditor. The two need a shared transaction list so the figures reconcile.

Does a downward adjustment on the CTDF increase audit risk?

It can attract attention, because a downward adjustment reduces Saudi taxable income. The rationale should be documented before the CTDF is submitted, not reconstructed afterwards.

Conclusion

For a UAE group with Saudi operations, the CTDF is small in size but large in consequence. It has no threshold, it shares the return's 120-day deadline, and it carries an Arabic auditor affidavit that forces the disclosure, the accounts, and the documentation to agree before ZATCA ever sees them. It is also the authority's first read on your transfer pricing position, which makes consistency and method selection worth getting right even where the underlying pricing is sound.

The encouraging point is that the CTDF rewards preparation rather than complexity. A UAE HQ that maps its Saudi related-party flows, reconciles the numbers early, engages the auditor in time, and keeps the Saudi and UAE disclosures telling the same story can meet the obligation without a scramble. Throughout, it is worth separating the confirmed features of the Saudi regime from details that depend on the specific entity and year, and confirming the precise thresholds, deadlines, and retention rules with current ZATCA guidance and the UAE Ministry of Finance Corporate Tax and FTA legislation sources for the UAE side. You can also review current UAE guides on the FTA guides and references page and confirm the domestic and cross-border reach of the rules in the FTA Corporate Tax FAQs.

To align your Saudi CTDF with your UAE transfer pricing position before the next filing, 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.

22/4/26 Qatar Extends the 2025 Tax

Page Title: Qatar Extends the 2025 Tax Return Deadline to 30 June 2026: What UAE Groups Need to Know
Meta Title: Qatar 2025 Tax Return Extension: A Guide for UAE Groups
Meta Description: Qatar moved the 2025 tax return deadline to 30 June 2026. Here is what UAE businesses with Qatar entities should do, and how it fits GCC compliance.
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