31 Aug. - 20 Sep.

Transfer Pricing Bylaws in the Kingdom of Saudi Arabia

Webinar recording

Transfer Pricing (TP) continues to be an evolving topic in the Kingdom of Saudi Arabia (KSA), where the authorities have led with the introduction of TP regulations and conducted focused TP audits. The Zakat, Tax and Customs Authorities (ZATCA) have also recently issued a public consultation document proposing to bring some amendments to the KSA TP Bylaws. These changes are aimed at entities that are paying Zakat to now adhere to the TP regulations.

Given the importance of this update, Deloitte held a webinar n both English and Arabic on Wednesday, 31 August and Tuesday, 20 September 2022 where our TP specialists discussed the proposed amendments on the KSA TP Bylaws and provided businesses with insight on how to start preparing for this important change.


Mohamed Serokh

Mohamed Serokh

Middle East Growth Tax Leader | Middle East Transfer Pricing Leader

As the Growth Leader for our Tax Services practice, Mohamed is a key member of our leadership team, responsible for spearheading our growth strategy in the Middle East. This includes strategy to identify and pursue new market opportunities, creating and implementing business development initiatives, reflecting the latest industry trends, and collaborating with the wider tax leadership team to achieve revenue growth targets. As Growth tax Leader, Mohamed is also responsible for leading strategy on accelerating our growth platform, proposal management, driving and promoting client excellence, and promoting our capabilities and industry leadership through marketing and eminence efforts.  In addition to spearheading our growth initiatives, Mohamed leads our award-winning and market-leading regional Transfer Pricing team. The team’s transfer pricing services span three key areas: consulting, controversy and compliance, and supporting clients in all industries and sectors. As a Transfer Pricing specialist and a former regulator, Mohamed has more than 25 years’ experience in transfer pricing, international tax, strategic, economic and business consulting across a number of industry segments. These include the automotive, construction and materials, energy, financial services, pharmaceutical, telecommunications and media, technology and travel and leisure sectors. His experience includes leading and managing global documentation and planning studies, as well as drafting Advanced Pricing Agreements (APAs) for submission to tax authorities in jurisdictions worldwide. Mohamed presents widely on transfer pricing and tax issues at seminars across the world and has been extensively published in the area of transfer pricing and tax on different platforms. In 2020, Mohamed was awarded the International Tax Review (ITR) Editor’s Choice Award for progressive work throughout the Middle East in Transfer Pricing and was nominated for the EMEA Transfer Pricing Practice Leader of the Year award. Mohamed was awarded an MBA (with distinction) from Warwick Business School, where he won an award for the overall best MBA degree of the year. Mohamed also holds MSc Economics (with distinction) and BSC Economics (first class) degrees from the University of London.

Danial Khalid

Danial Khalid

ME Technology, Media and Telecommunications Tax Leader | KSA Transfer Pricing Leader

Danial is a seasoned tax professional, leading Deloitte’s transfer pricing practice in the Kingdom of Saudi Arabia (KSA). He also serves as the Technology, Media and Telecommunications Tax Leader at Deloitte Middle East and brings a wealth of industry knowledge and experience to his role, providing tailored tax solutions that help clients. Danial's understanding of the emerging trends and developments in the TMT sector, combined with his expertise in transfer pricing and international tax, enable him to understand each client’s unique needs and deliver customized tax solutions that align with their goals. He has over 15 years of experience in advising multinationals on transfer pricing and has worked across a number of jurisdictions including Singapore, Indonesia, United Arab Emirates (UAE), Bahrain and KSA. He has been operating in the Middle East since 2014. Danial has experience with many transfer pricing projects, encompassing TP design, audit defense, compliance and contemporaneous documentation for tangible property, intangible property, intercompany services, and debt pricing for clients in a diverse range of industries. He has also assisted clients in negotiating bilateral advanced pricing agreements.  Danial holds an MSc in Economics degree from the University of Kent, United Kingdom.

Joy Mukherjee

Joy Mukherjee

Director | Transfer Pricing

Joy is an experienced Transfer Pricing (TP) professional with 15 years of experience. Over the past few years, Joy has advised clients across industry segments in setting up appropriate TP arrangements involving inter-company transactions, compliance with the in-country legal requirements and the guidelines stipulated by the Organization for Economic Cooperation and Development (OECD) and negotiated with tax authorities to achieve the optimum outcome for clients. Joy has a great depth of international experience having worked in India, the United Kingdom (UK), Vietnam, and Australia before moving to the Middle East. 

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31 Aug. - 20 Sep. 2022
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