In this Part 3, we explore the KSA’s historic approach to penalties and the motivation to develop transfer pricing-specific penalties. For sake of illustration, we will review the IRS reasons for enactment of transfer pricing-specific penalties, the substance of those penalties, and the IRS...

As part of an increased openness to international investment and the resulting need to address international tax issues, the Kingdom of Saudi Arabia (KSA) recently adopted transfer pricing regulations consistent with global norms. Due to the newness of these regulations in the KSA tax system and...