Article 66 - Tax Returns

A Filing Constituent Entity shall file a Tax Return to the Bureau for each Reporting Fiscal Year, no later than 15 months from the last day of the Reporting Fiscal Year.

The Tax Return shall be submitted on a form prescribed by the Bureau for this purpose, and which is aligned with the requirements specified in the Model Rules, Administrative Guidance, Commentary, or any relevant guidelines issued or which may in future be issued by the OECD.

The Filing Constituent Entity shall disclose the following information in its Tax Return:

1. A Tax Computation Schedule, which includes a self-assessment of Tax Due to the Bureau for the Fiscal Year.

2. An Information Schedule, which includes, where applicable, information related to Constituent Entities, Joint Ventures and Joint Venture Subsidiaries which are members of the Multinational Enterprise Group, and which may be located outside the Kingdom.

3. Any other information specified by the Bureau.

A Filing Constituent Entity may submit a Tax Return solely comprising a Tax Computation Schedule, if an Information Schedule which adheres to the requirements stipulated in the Model Rules, Administrative Guidance, Commentary and guidelines issued by the OECD has been submitted by any of the following Entities:

1. The Ultimate Parent Entity of the Multinational Enterprise Group which is located in a jurisdiction that has a Qualifying Competent Authority Agreement in effect with the Kingdom for the Reporting Fiscal Year.

2. A Constituent Entity of the Multinational Enterprise Group, other than the Ultimate Parent Entity, which is located in a jurisdiction that has a Qualifying Competent Authority Agreement in effect with the Kingdom for the Reporting Fiscal Year.

Where Paragraph D of this Article applies, the Tax Return submitted by a Filing Constituent Entity shall include the identity and location of the Entity which filed the information as set out in Clauses 1 and 2 of Paragraph D of this Article. The Bureau may request the Filing Constituent Entity to supplement a submitted Tax Return where the Bureau does not receive all the required information pursuant to a Qualifying Competent Authority Agreement.

For the purposes of applying the provisions of the preceding Paragraphs of this Article, a Qualified Competent Authority Agreement is a bilateral or multilateral agreement or arrangement between competent authorities that provides for the automatic exchange of Information Schedules which adhere to the requirements stipulated in the Model Rules, Administrative Guidance, Commentary, and guidelines issued by the OECD.

An Excluded Entity registered pursuant to Paragraph C of Article 17 of the Law shall submit a declaration on the form and manner prescribed by the Bureau which shall include information and supporting documents sufficient to substantiate that Entity's status as an Excluded Entity.

Without prejudice to the preceding paragraphs of this Article, the Bureau may, for Fiscal Years beginning on or before 31 December 2028, but not for any Fiscal Year that ends after 30 June 2030, allow a Filing Constituent Entity to submit a simplified Tax Return which contains information prescribed by the Bureau and which is consistent with the Model Rules, Administrative Guidance, Commentary or any relevant guidelines issued or which may in future be issued by the OECD.