Saudi Arabia’s tax amnesty is entering its final months

What could follow the December deadline is an assessment cycle, not a filing cycle.

By Manish Bansal, Associate Partner, Dhruva Advisors, A Ryan Affiliate, Saudi Arabia

For most of the past five years, inter-alia, one of the major topics of tax conversation in Saudi boardrooms has been e-invoicing. Are we on the Fatoora platform? Which wave are we in? Has the ERP been configured or do we go with a third-party e-invoicing solution? Will we make the deadline?

Those were the right questions for the period we have just left. They are not necessarily the right questions for the period we are entering.

On 29 June 2026, the Zakat, Tax and Customs Authority (“ZATCA”), acting on a decision of the Minister of Finance, extended the Cancellation of Fines and Exemption of Financial Penalties initiative for a further six months, running from 1 July to 31 December 2026. It covers excise tax, value added tax, real estate transaction tax, withholding tax and corporate income tax. That much has been widely reported.

Less widely noticed is a condition set out in the accompanying guideline. If the Authority extends the initiative again past December, that further extension will not reach returns that fell due after 30 June 2026.

The Authority has not simply granted more time. It has informed the market, in advance, where the relief eventually stops. Whatever is announced in December, the clean-up window for historical positions is being drawn shut. For a tax administration, that is about as clear a statement as one can give.

What the regulator already sees

The reason this matters now, rather than in some indeterminate future, is that the Authority’s information position has changed fundamentally.

Wave 24 of the e-invoicing Integration Phase closed on 30 June 2026. Announced in September 2025, it captured every taxpayer whose VAT-subject revenues exceeded SAR 375,000 in 2022, 2023 or 2024. That figure is not arbitrary: it is the mandatory VAT registration threshold. In effect, the wave brought the entire registered population into scope.

And the direction has not stopped there. On 24 July 2026 – ZATCA published the criteria for Wave 25, halving the threshold to SAR 187,500 of VAT-subject revenue in 2022, 2023, 2024 or 2025, with integration required by 1 February 2027.

Under the Integration Phase, standard business-to-business invoices are cleared by ZATCA before they reach the buyer, and simplified business-to-consumer invoices are reported within twenty-four hours. Invoices must be issued in a prescribed structured format, carrying a cryptographic stamp and a unique identifier.

The Authority is therefore no longer reliant on what appears in a filed return. It holds the underlying transactional record, in structured form, close to real time, across the whole economy.

This is the shift most finance functions have not yet absorbed. For years, the Saudi assessment process began with an information request. In an environment of structured, near-live data, it begins instead with an anomaly the system has already identified. The taxpayer’s first substantive contact with the process is not a request for documents. It is a proposition to be answered.

Key exposure areas to be mindful of

In our experience, the following key areas could be more visible and exposed to assessment risk in the Kingdom once transactional data can be cross matched against declarations.

The first is permanent establishment risk arising from project delivery. Groups routinely deploy technical staff, secondees and subcontracted specialists into Saudi projects while treating the arrangement as an offshore supply.  Given that most KSA government portals are inter-linked, careful monitoring of in-Kingdom presence is critical, in particular, employees of non-resident companies undertaking fly-in/fly-out assignments in the Kingdom.  It is worth noting that the current tax law has no de minimis threshold for the creation of a permanent establishment.  Accordingly, even a single day of presence in the Kingdom could potentially give rise to a permanent establishment, although in practice, the ZATCA may apply a more facts-based approach when assessing whether a permanent establishment exists.

Second is related-party pricing, and here a change that took effect two years ago is still under-appreciated. Following amendments to the Transfer Pricing By-Laws, the transfer pricing provisions apply to zakat payers as well as taxpayers for financial years beginning on or after 1 January 2024, and Advance Pricing Agreements became available to both. For a Saudi family group with decades of intercompany arrangements built for operational convenience rather than for documentation, this is a material change in obligation, and one that many such groups have not yet worked through.

Lastly, needless to state that VAT audits are likely to get much more sophisticated with real time data and the data analytics and AI tools available.

What the amnesty covers, and what it does not

Many companies are counting on this window. It is worth being precise about what it covers.

The initiative covers late registration, late payment and late filing fines, penalties on the amendment or correction of a VAT return, and other financial fines imposed under Article 45 of the VAT Law, including field detection and e-invoicing violations. To benefit, a taxpayer must register where registration is required, submit the outstanding returns, and either pay the amounts due or obtain ZATCA’s approval for an instalment plan.

Two limits deserve emphasis. The initiative does not extend to penalties relating to tax evasion violations. And it operates on fines for returns falling due up to 30 June 2026.

There is also a point that no guideline states because it does not need to. The initiative waives penalties. It does not validate a technical position. A voluntary disclosure that corrects an arithmetic omission is a straightforward matter. A voluntary disclosure that reveals a contestable tax treatment is a different exercise entirely, because it puts a position on the record that will be read. The analysis must come before the filing, not after it.

Fewer than four months

For most groups, what remains to be done before 31 December is a short list. It is also, notably, not a systems exercise. The e-invoicing platforms are already built and connected. The work now is reviewing the positions those systems have been reporting all along.

Reconcile first. Take VAT/ Tax/ Zakat returns, customs declarations, withholding tax filings and audited financial statements for the open years and reconcile them against one another before ZATCA’s systems do it. Where the numbers do not tie, understand why, and document the reason contemporaneously rather than reconstructing it under assessment.

Then sort. Separate the genuine errors, which the current window is designed to resolve, from the judgement positions, which need to be assessed on their merits and defended with evidence that pre-dates the query.

Finally, treat documentation as a deliverable with a deadline. Substantiation assembled after an assessment notice arrives carries markedly less weight than substantiation prepared when the transaction occurred.

A regulator that publishes wave criteria six months ahead, that notifies taxpayers directly, that issues guidance with worked examples, and that tells the market in advance where relief will end, is behaving like the administration of a mature investment destination. That predictability is an asset for serious businesses, and it is what long-term capital looks for.

But predictability runs in both directions. The Kingdom has been clear about what it expects and when. The businesses that will move through the coming assessment cycle with least disruption are those that use the next few months to answer the questions before they are asked.