GTL Summary:

Document Type: IR - Implementing Regulations
Law: Value Added Tax Law
Decision Number: 3839-article-10
Year: 2016
Country: 🇸🇦 KSA
Official Name: Article 10 - Registration of Tax Groups
Last updated at: 2025-11-27 14:38:44 UTC

Chapter 2 - Taxpayers

Article 10 - Registration of Tax Groups

  1. Two or more legal persons may apply for registration as a tax group for value added tax purposes in the Kingdom, provided that all of the following requirements are met:[10]

    1. Each of them must be resident in the Kingdom and have the right to register as a taxable person in accordance with the provisions of these Regulations.

    2. Fifty per cent (50%) or more of the capital, voting rights, or market value of each legal person in the group is owned - directly or indirectly - by the same legal person or legal persons, or one of the legal persons in the group or outside it has the power to control and dominate the other persons in the tax group.

    3. None of the members of the group shall be licensed to operate in any special zone enjoying customs suspension status, in accordance with the regulations relating to those zones, and/or be a member of another tax group.

    4. Neither the applicant nor any member of the group shall be a person eligible for refund in accordance with the provisions of Article 70 of these regulations, with the exception of:

      1. A person who is considered eligible for recovery as a licensed real estate developer whose licensed real estate activity is limited to real estate supplies by way of sale and transfer of ownership exclusively to his employees.

      2. A person who has been deemed eligible for recovery as a donor to public benefit projects.

  2. All the requirements set out in paragraph (1) of this Article must continue to be met by all members of the group throughout the period of registration of the tax group as a taxable person. [11]

Footnotes

[10]Paragraph 9 was amended by Decision No. (01-06-24) of the Board of Directors of the Zakat, Tax and Customs Authority on 17 Jumada Al-Awwal 1446 AH, corresponding to 19 November 2024 AD. Prior to the amendment, Paragraph 9 read as follows:

  1. 'Two or more legal Persons may apply to register as a Tax Group, for VAT purposes in the Kingdom if the following requirements are met:

    1. Each legal Person is resident in the Kingdom and carries out an Economic Activity,

    2. Fifty percent (50%) or more of the capital of each legal Person, or ownership or control of fifty percent (50%) or more of the voting rights or value, in both or all of the legal Persons, is held by the same Person or group of Persons, whether, in any of the foregoing cases, directly or indirectly,

    3. At least one of the legal Persons is a Taxable Person.'

[11]The paragraph was added pursuant to the decision of the Board of Directors of the Zakat, Tax and Customs Authority by circular No. (01-06-24) on 17 Jumada Al-Awwal 1446 AH, corresponding to 19 November 2024 AD

Fast-loading version for search engines - Click here for the interactive version