GTL Summary:

Issued by the Board of Directors of the Zakat, Tax, and Customs Authority, this Decision adds Article 32 bis to the Implementing Regulations of the Value Added Tax Law. The new article details the VAT treatment for goods under customs suspension arrangements. It stipulates that supplies to or within such arrangements, including qualifying special zones, are zero-rated. Tax on importation is suspended until the goods are released from customs suspension. The article establishes specific conditions for special zones, outlines taxpayer documentation requirements, and clarifies that utilities are excluded from this treatment, aligning VAT procedures with the Unified Customs Law.

Document Type: IR - Implementing Regulations
Law: Value Added Tax Law
Decision Number: implementing-regulations-3839-article-32-bis
Year: 2016
Country: 🇸🇦 KSA
Official Name: Article 32 bis - Suspension of Tax on Import and Supply Transactions Related to Tax Suspension
Last updated at: 2026-01-05 08:39:39 UTC

Chapter 6 - Zero-Rated Supplies

Article 32 bis
Suspension of Tax on Import and Supply Transactions Related to Tax Suspension [41]

  1. The supply of goods to any of the customs suspension arrangements shall be subject to a zero rate, and the supply of goods within such arrangements shall be in accordance with the provisions of the Unified Customs Law.

  2. The re-export of goods that have been temporarily imported into the Kingdom for repair, restoration, treatment, or processing shall be subject to zero percent tax, provided that the provisions and procedures stipulated in the Unified Customs System are met.

  3. Tax due on the importation of goods placed under customs suspension arrangements shall be suspended if the conditions for suspension stipulated in the Unified Customs Law are met. The tax becomes due upon the release of the goods from customs suspension, in accordance with the conditions and procedures stipulated in the Unified Customs Law.

  4. Goods exported from any of the customs suspension arrangements to outside the GCC territory shall be treated as exports of goods and subject to the export treatment applicable to such goods.

  5. Without prejudice to any other provisions stated in the applicable laws of the Kingdom, the same tax treatment provided for in paragraphs (1), (2), (3), and (4) of this Article shall apply to the importation of goods into, or the supply of goods to, or within, any of the special zones, or between two special zones, or when goods are removed from customs suspension or from the GCC territory—depending on the nature of the transaction—provided that all of the following conditions are met:

    1. The special zone must be one that enjoys customs suspension status in accordance with the provisions of the Unified Customs Law.

    2. The goods must be related to the licensed activities carried out in the zone, in accordance with the regulatory provisions issued concerning the special zone.

    3. The goods must be placed under one of the customs suspension arrangements in accordance with the provisions of the Unified Customs Law.

    4. The special zone must have procedures in place to monitor the movement and supply of goods into, within, and out of the zone.

  6. Invoices and documents related to supplies within special zones must be retained in accordance with the provisions of this Regulation.

  7. For the purposes of applying the provisions of this article, the taxpayer must keep all documents proving the location of the goods at the time of supply and proving their transfer and placement under any of the customs duty suspension regimes or from or within them - including those relating to special zones - and shall include, in particular, customs documents issued in accordance with the provisions and procedures of the Unified Customs System.

  8. The provisions of this Article shall not apply to water, electricity, or all forms of energy, including gas, lighting, heating, cooling, or air conditioning, which are not subject to customs suspension procedures.

Footnotes

[41] This Article was added pursuant to the decision of the Board of Directors of the Zakat, Tax, and Customs Authority No. (01-06-24) dated 17 Jumada al-Awwal 1446 AH, corresponding to 19 November 2024 AD.

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