General Documentation is Saudi Arabia's catch-all transfer pricing record for taxpayers who fall below the Local File and Master File thresholds but still transact with related parties. Set out in Article 19 of the KSA Transfer Pricing Bylaws, it has no prescribed template, yet it must still prove every controlled transaction was priced on an arm's length basis, and it has to reach ZATCA within 30 days of a request.
Key takeaways
- General Documentation is required from taxpayers and zakat payers that have related-party transactions but are exempt from the Local File and Master File, including natural persons, zakat-exempt entities and investment funds.
- It has no fixed format, but it must contain enough to verify the arm's length nature of each controlled transaction, in particular the functional and economic analysis.
- Its purpose is identical to the Local File: to let ZATCA confirm that related-party pricing is at arm's length.
- Documentation must be produced within 30 calendar days of a ZATCA request, not business days.
- ZATCA is more likely to ask for it where there are special economic zone counterparties, artificial arrangements, corresponding-adjustment requests or international information-exchange obligations.
Why "exempt" does not mean "off the hook"
General Documentation is why a Local File exemption is never a clean pass. The exemption lifts a filing format, not the arm's length principle. The regime exists to catch transactions sitting below the Local File threshold, so no related-party dealing escapes arm's length testing. A small trading company, a natural person doing business in the Kingdom, a zakat-exempt entity or an investment fund can each fall outside the Local File regime and still have to show, on request, that its intercompany pricing was reasonable.
The practical standard is lighter in form but not in substance. ZATCA does not hand you a template, and any format that does the job is acceptable. What it does expect is content: the identity of the related parties and the nature of each controlled transaction, how the price was arrived at, and why the terms are consistent with what independent parties would have agreed. In practice, SBC advisers keep information close to what a Local File would contain, especially the functional analysis and the economic (benchmarking) analysis, because a proportionate file assembled early costs far less than reconstructing one inside a 30-day window.
A fund that on-lends to a portfolio company, or an owner-managed business that buys from a related supplier, still has to be able to show, on request, that the interest rate or the margin was set on commercial terms rather than to shift profit. The lighter format simply means that a proportionate, well-reasoned file is enough, not that no file is needed.
Local File versus General Documentation
The two obligations are cousins, not twins. They share a purpose and a timeline but differ in who prepares them and how prescriptive they are. Seeing them side by side makes the boundary clear.
| Feature | Local File | General Documentation |
|---|---|---|
| Who prepares it | Taxpayers and mixed entities above SAR 6m; zakat payers above the phased thresholds | Taxpayers and zakat payers below the Local File threshold, including natural persons, zakat-exempt entities and investment funds |
| Format | Prescribed, OECD-style content | No prescribed format |
| Purpose | Confirm each controlled transaction is at arm's length | The same |
| Timeline | Maintained by the return-filing date; produced within 30 days of a request | The same |
Whether you are above or below the Local File line, ZATCA wants to be able to confirm the arm's length nature of your controlled transactions, and the transfer pricing evidence you keep is what makes that possible.
When ZATCA is most likely to ask
Format-free does not mean preparation-free. You have 30 calendar days from a ZATCA request to produce documentation, and that clock does not care that no template was prescribed. Assemble the functional and economic analysis before the request arrives.
ZATCA is more inclined to ask for General Documentation where a counterparty sits in a special economic zone, where arrangements look fictitious or artificial, where a corresponding adjustment is being sought after another authority has adjusted the other side of a transaction, or where international information obligations are in play. Cross-border structures naturally attract more attention, so groups with international tax exposure should keep their evidence current even when the Local File does not apply. The 30-calendar-day production window is short by design, and it applies just as firmly to General Documentation as to the Local File.
Frequently asked questions
Who must prepare General Documentation in Saudi Arabia?
Any taxpayer or zakat payer with related-party transactions that is exempt from the Local File and Master File, including natural persons, zakat-exempt entities and investment funds. It is the fallback documentation that keeps below-threshold taxpayers within reach of the arm's length principle.
Does General Documentation have a required format?
No. ZATCA does not prescribe a template, and any format that meets the requirements is acceptable. It must, however, include enough information to verify the arm's length nature of each controlled transaction, especially the functional analysis and the economic or benchmarking analysis.
How quickly must General Documentation be provided?
Within 30 calendar days of a ZATCA request, not business days. Because the window is short and no template is provided, the sensible approach is to prepare and keep the analysis contemporaneously rather than waiting for the request.
How is General Documentation different from the Local File?
They share the same purpose and 30-day timeline, but the Local File is a prescribed, OECD-style document required above the thresholds, while General Documentation is a format-free record required below them. Both must demonstrate that controlled transactions are at arm's length.
How SBC Tax Consulting can help
SBC prepares compliant General Documentation that evidences every related-party transaction with robust FAR and economic analysis, so below-threshold taxpayers stay audit-ready even without a full Local File. We tailor the content to your transactions, keep it consistent with your disclosure form, and stand ready to support any ZATCA review or dispute. To discuss your transfer pricing position, 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.