SA Return Assembly

Saudi Arabia — Return Assembly (Capstone) — Skill v1.0

CRITICAL EXECUTION DIRECTIVE — READ FIRST

When this skill is invoked, the user has already passed through intake and the relevant content skills. They want their finished ZATCA working paper. Execute all steps without pausing for permission.

Specifically:

• Do NOT ask "do you want me to assemble the full package". The user asked for the return. Produce it.
• Do NOT re-interrogate the user about residency, CR number, TIN, or ownership structure — intake already captured this; trust the upstream packages.
• Do NOT pause between reconciliation steps to check in. Run all cross-checks in sequence; flag failures in the reviewer brief and continue.
• Self-checks are targets, not blockers. If a check fails, note it under "Reviewer Attention Flags" and continue.
• Do NOT submit anything to ZATCA. This skill produces a working paper plus filing instructions. A credentialed reviewer (SOCPA member, or recognised ICAEW / ACCA / US CPA practising in KSA) must review, and the taxpayer (or authorised representative) submits via the ZATCA portal.

If you feel the urge to ask "how should I proceed", pick the most defensible path, proceed, and flag the decision for the reviewer.

What this file is

The final capstone skill for Saudi Arabian annual tax filings. It consumes the outputs of every other Saudi skill and assembles a single unified working paper covering one of:

• Zakat declaration — Saudi-owned and GCC-owned entities under Royal Decree No. M/40 (1405 AH) and the Implementing Regulations for Zakat Collection issued by ZATCA
• Corporate Income Tax return (Form 800 series) — foreign-owned (non-Saudi / non-GCC) entities under the Income Tax Law (Royal Decree No. M/1 of 1425 AH) and its Implementing Regulations
• Mixed-entity return — joint Saudi / foreign ownership; Zakat applied to the Saudi/GCC share, CIT applied to the foreign share, on a single combined return

The output is a reviewer-ready package: line-by-line ZATCA working paper, cross-skill reconciliation table, payment instructions (ZATCA portal → SADAD billing ID → Saudi bank channel), filing instructions, reviewer checklist, taxpayer action list, WPS / Saudization compliance check, and 2026 planning notes.

Section 1 — Quick reference

Section 1 — Quick reference table

Field	Value
Country	Kingdom of Saudi Arabia
Tax authority	Zakat, Tax and Customs Authority (ZATCA) — formerly GAZT and Saudi Customs, merged in 2021
Filing portal	ZATCA portal — https://zatca.gov.sa
Currency	SAR (Saudi Riyal)
Tax year (default)	Gregorian calendar year (1 Jan – 31 Dec); some entities approved for Hijri year; financial year of taxpayer if different by approval
Current tax year	2025 (filing window opens 1 January 2026)
Annual return deadline	Within 120 days of fiscal year-end (Gregorian 31 December year-end → 30 April 2026)
Zakat declaration	Annual; due within 120 days of FYE
CIT return	Annual Form 800 series (Form 8 and variants); due within 120 days of FYE
Mixed-entity return	Zakat portion + CIT portion on the same combined annual return
VAT return	Monthly (mandatory if turnover > SAR 40 million) or quarterly (smaller taxpayers); due by 28th of month following the period
WHT return	Monthly; due within 10 days of month-end
Excise return	Bi-monthly; due within 15 days of period-end
RETT (Real Estate Transaction Tax)	Transaction-by-transaction at notarisation; 5% on real estate disposals
Confirmation receipt	ZATCA portal acknowledgement with submission reference and timestamp
Payment channel	ZATCA portal generates SADAD bill (with billing ID) → pay via any Saudi bank, internet banking, mobile app, or SADAD-enabled ATM
Audited financial statements	Required for entities above ZATCA thresholds (typically SAR 40M+ revenue; thresholds vary by entity type)
Governing law	Zakat — Royal Decree M/40 (1405 AH) + Zakat Collection Implementing Regulations; CIT — Royal Decree M/1 (1425 AH) Income Tax Law + Implementing Regulations; VAT — Royal Decree M/113 (1438 AH); Excise — Royal Decree M/86 (1438 AH); RETT — Royal Decree M/84 (1442 AH)
Skill version	1.0
Validated by	Pending — requires sign-off by SOCPA member (Saudi Organization for Chartered Public Accountants) or recognised ICAEW / ACCA / US CPA practising in KSA

1.1 What this capstone produces

A single reviewer-ready package containing:

1. Master working paper (Excel) — ZATCA-aligned schedules, cross-skill reconciliation, SADAD billing register
2. Reviewer brief (Markdown) — executive summary, Zakat / CIT / mixed split walk-through, positions taken, attention flags
3. Taxpayer action list (Markdown) — payments to make (SADAD bills to settle), ZATCA portal submission steps, deadlines, WPS / Saudization confirmations, record retention
4. 2026 planning notes — VAT periodicity check, WHT monthly cadence, advance Zakat / CIT planning, Saudization tier maintenance, working capital optimisation for Zakat

Section 2 — Required inputs from upstream SA skills

The assembly skill does not recompute anything. It expects structured outputs from the following upstream Saudi skills. If an upstream skill did not run, the assembly notes the gap and continues with available data.

2.1 Entity-type matrix — which upstream skills feed which return

Entity-type matrix table

Entity ownership	Annual filing	Upstream skills consumed
100% Saudi / GCC-owned	Zakat declaration only	sa-zakat, saudi-arabia-vat, sa-withholding-tax, sa-gosi-saudization, sa-formation, saudi-einvoice
100% foreign-owned	CIT return (Form 800)	sa-corporate-tax, saudi-arabia-vat, sa-withholding-tax, sa-gosi-saudization, sa-formation, saudi-einvoice
Mixed (Saudi/GCC + foreign)	Combined Zakat + CIT return — proportional split by ownership	sa-zakat AND sa-corporate-tax, plus all others
Listed on Tadawul with mixed shareholders	Combined Zakat + CIT — proportional by free float	sa-zakat AND sa-corporate-tax, plus others
Real estate disposer in the year	+ RETT computation	sa-rett
Excise-taxable goods (tobacco, sugary drinks, energy drinks, soft drinks, sweetened beverages, e-cigarettes, electronic devices for vaping)	+ Excise return	sa-excise-tax

2.2 Zakat declaration — inputs

Zakat declaration inputs table

Upstream skill	Output consumed	Where it lands on the Zakat declaration
sa-zakat	Zakat base computation: equity-method base (capital + retained earnings + reserves + long-term liabilities − long-term assets − adjustments) OR Zakat-on-profit base where lower; 2.5% Zakat rate (or 2.577% Hijri-year conversion); working capital adjustments	Main Zakat base schedule; Zakat liability line
saudi-arabia-vat	VAT-registered turnover; output VAT and input VAT positions (cross-check only)	Cross-check vs. revenue in financial statements
sa-withholding-tax	WHT suffered (rare for Saudi/GCC entities other than payments from abroad) and WHT agent obligations on payments to non-residents (5%/15%/20% by category)	WHT credits schedule; agent compliance check
sa-gosi-saudization	GOSI contributions (employer + employee), Saudization tier (Nitaqat: Platinum / High Green / Medium Green / Low Green / Yellow / Red), WPS file submissions via Mudad	Salary & wage schedule; compliance attestation
sa-rett	Real estate transaction tax paid on disposals during the year (5% RETT)	Disclosure schedule; not Zakat-deductible
sa-excise-tax	Excise paid and collected on taxable goods	Cross-check only — separate return
sa-formation	Entity structure: Commercial Registration (CR) number, TIN, MoC registration, shareholders' nationality split, paid-up capital	Identification block; ownership split for mixed entities
saudi-einvoice	E-invoicing compliance status (Fatoorah Phase 1 generation + Phase 2 integration with ZATCA)	Compliance attestation

2.3 CIT return (foreign-owned entities) — inputs

CIT return inputs table

Upstream skill	Output consumed	Where it lands on the CIT return
sa-corporate-tax	CIT computation: accounting profit → taxable income via tax adjustments; CIT at 20% (general rate); 85% rate for upstream oil & gas; 30%–85% rate for natural gas investment field; permanent establishment determination	Form 800 — main computation; tax adjustments schedule; depreciation schedule (under SA Income Tax Law Implementing Regulations)
sa-withholding-tax	WHT suffered (rare) and WHT agent obligations on payments to non-residents (5% royalties / 15% management fees / 20% other / 5% dividends / 5% interest — per ITL Art. 68)	Tax credits schedule; agent compliance check
saudi-arabia-vat	Output and input VAT; VAT return reconciliation	Cross-check vs. revenue
sa-gosi-saudization	Employee GOSI, salary expense, Saudization tier compliance	Salary schedule; compliance attestation
sa-rett	RETT paid on disposals (deductible or capitalised per accounting policy)	Disclosure schedule
sa-excise-tax	Excise tax paid / collected	Cross-check only
sa-formation	CR number, TIN, MoC registration, shareholders' nationality, paid-up capital	Identification block
saudi-einvoice	Fatoorah compliance status	Compliance attestation

2.4 Mixed-entity return — proportional split

Mixed-entity proportional split table

Calculation step	Treatment
1. Compute the Zakat base (equity method)	Per sa-zakat
2. Compute the CIT taxable income	Per sa-corporate-tax
3. Determine ownership split	From sa-formation (cap table at year-end)
4. Apply Zakat to Saudi/GCC share of Zakat base × 2.5%	Zakat portion
5. Apply CIT to foreign share of CIT taxable income × 20% (or applicable rate)	CIT portion
6. Add WHT agent obligations	Same for both portions
7. Combined liability on a single return submitted via ZATCA portal	One submission

2.5 Intake-required identifiers

Intake-required identifiers table

Identifier	Required for
Commercial Registration (CR) number — issued by Ministry of Commerce	All entities
Tax Identification Number (TIN) — issued by ZATCA	All entities
VAT registration number — 15 digits ending in 03	If VAT-registered
ZATCA portal credentials (username + password + nafath / IAM)	All electronic submissions
MoC commercial registration certificate	All entities
Shareholders' nationality split (Saudi / GCC / foreign)	Mixed-entity determination
Fiscal year-end date	Determines 120-day deadline
Audited financial statements (where threshold met)	All entities above the SAR 40M revenue threshold (or other ZATCA-specified thresholds)
GOSI employer registration	All entities with employees
Mudad subscription (WPS platform)	All entities with employees
Nitaqat tier (Saudization)	Entities with 5+ employees
Saudi Customs importer / exporter identifier	If applicable

• Missing identifier handling — If any identifier is missing, the assembly skill flags it as "Needs Input" and produces the working paper with placeholders rather than halting.

Section 3 — Assembly workflow

The capstone runs in eight phases. Each phase reads upstream output, runs reconciliation, and writes a section of the master working paper.

3.1 Phase 1 — Read intake & confirm scope

0. Phase 1 — Confirm entity type: Saudi/GCC-owned / foreign-owned / mixed; confirm fiscal year-end (Gregorian default; Hijri or custom by ZATCA approval); compute the 120-day deadline from FYE; confirm whether RETT, Excise apply; confirm VAT periodicity (monthly if turnover > SAR 40M; otherwise quarterly)

3.2 Phase 2 — Ownership split (for mixed entities)

0. Phase 2 — Read cap table from sa-formation; classify each shareholder as Saudi / GCC / foreign; compute Saudi+GCC % and foreign %; carry to mixed-entity computation

3.3 Phase 3 — Zakat base or CIT taxable income

0. Phase 3 — For Saudi/GCC-owned (Zakat only): Read Zakat base from sa-zakat (equity method or Zakat-on-profit, whichever lower under Implementing Regulations Art. 5); apply 2.5% rate (Gregorian) or 2.577% (Hijri-year filers). For foreign-owned (CIT only): Read CIT taxable income from sa-corporate-tax; apply 20% general rate (or specialised rates: 85% upstream petroleum; 30% natural gas); apply interest deduction limitation: 50% of EBITDA per ITL Art. 12 / Implementing Regulations; apply carry-forward loss rules: 25% annual cap per year against current-year income, no time limit on the loss. For mixed: compute both bases independently; apply proportional ownership split

3.4 Phase 4 — Withholding tax compliance

0. Phase 4 — Read WHT agent obligations from sa-withholding-tax; verify monthly WHT returns filed within 10 days of month-end for each month of the year; reconcile total WHT remitted vs. total payments to non-residents × applicable rate. Common rates (ITL Art. 68): Royalties: 15%; Management / consulting fees to non-resident: 20% (5% if related party — verify); Dividends to non-resident: 5%; Interest to non-resident: 5%; Technical / consulting services: 5%; Rent: 5%; Other: 15% or 20% (verify per category)

3.5 Phase 5 — VAT reconciliation

0. Phase 5 — Annual VAT-able revenue per saudi-arabia-vat should equal financial statement revenue (after standard reconciling items: zero-rated exports, exempt items, output adjustments); annual output VAT vs. sum of monthly/quarterly returns; annual input VAT vs. sum of returns; net VAT position: refundable or payable

3.6 Phase 6 — GOSI, Saudization, WPS

0. Phase 6 — Read GOSI contributions from sa-gosi-saudization; confirm WPS files submitted via Mudad for every month of the year; confirm Nitaqat tier (Platinum / High Green / Medium Green / Low Green / Yellow / Red) for entities with 5+ employees; Yellow/Red tier flags consequences: visa restrictions, work permit renewal issues, ZATCA may flag the file

3.7 Phase 7 — RETT and Excise (if applicable)

0. Phase 7 — RETT: per sa-rett — 5% of real estate disposal value, paid at notarisation; disclosure only on the annual return. Excise: per sa-excise-tax — bi-monthly returns; annual reconciliation. Tobacco: 100%; Soft drinks: 50%; Energy drinks: 100%; Sweetened beverages: 50%; Electronic smoking devices: 100%

3.8 Phase 8 — Final assembly

0. Phase 8 — Build master Excel workbook; write reviewer brief; write taxpayer action list; generate SADAD billing register; generate 2026 planning notes

Section 4 — Working paper structure (for credentialed reviewer)

The reviewer is a SOCPA member (Saudi Organization for Chartered Public Accountants) or a recognised foreign credential practising in KSA — ICAEW (UK), ACCA, or US CPA. They sign off before ZATCA submission. SOCPA is the primary local credential; foreign credentials are accepted by ZATCA for international firms and joint ventures.

4.1 Master workbook sheets

Master workbook sheets table

Sheet	Contents
Cover	Entity name, CR number, TIN, VAT number, fiscal year, return type (Zakat / CIT / Mixed), reviewer name, sign-off block
Identification	CR, TIN, VAT, MoC, GOSI employer ID, addresses, principal activity, NACE/ISIC equivalent
Ownership Split	Cap table at FYE; Saudi/GCC% and foreign%
Computation — Zakat	Equity-method base build; working capital adjustments; 2.5% application
Computation — CIT	Accounting profit → taxable income; tax adjustments; depreciation; interest deduction limit; loss carry-forward
Mixed-Entity Apportionment	Saudi/GCC share × Zakat; foreign share × CIT
WHT Schedule	All monthly WHT returns with SADAD billing IDs, payments to non-residents by category and rate
VAT Reconciliation	Monthly / quarterly VAT returns vs. annual revenue
GOSI & Saudization	Monthly GOSI returns, Nitaqat tier, WPS attestation
RETT (if applicable)	Each real estate disposal with notarisation date and 5% RETT paid
Excise (if applicable)	Bi-monthly excise returns; annual reconciliation
E-Invoicing (Fatoorah)	Phase 1 generation status; Phase 2 integration status
SADAD Billing Register	Every payment with tax head, period, amount, SADAD billing ID, payment date, bank receipt
Cross-Check Summary	Pass/fail for each reconciliation
2026 Planning	VAT periodicity, WHT monthly cadence, Saudization plan

4.2 Cross-skill reconciliations

• Reconciliation tolerance rule — Each cross-check must pass within tolerance (SAR 100 default; SAR 1,000 for larger entities). Failures flagged, not silently absorbed.

Cross-check 1 — Revenue reconciliation

Source	Figure	Rule
Financial statements revenue	Top of P&L	Anchor
sa-zakat / sa-corporate-tax revenue	Per upstream	Should equal anchor
saudi-arabia-vat aggregate annual output base	Sum of monthly/quarterly returns	Reconciles ± zero-rated exports, exempt sales, output adjustments
Bank deposits (if available)	Cross-check	Reconciles ± timing

Cross-check 2 — Salary, GOSI, WPS

Source	Figure	Rule
sa-gosi-saudization annual GOSI contributions	Sum of monthly returns	Anchor
sa-corporate-tax / financial statement salary expense	P&L salaries line	Reconciles to (gross salaries)
WPS file submissions via Mudad	12 monthly files	All present — no gaps
Nitaqat tier per Saudization	Per upstream	Confirm not Yellow / Red

Cross-check 3 — WHT agent obligations

Source	Figure	Rule
Total payments to non-residents (per accounting records)	Per upstream	Anchor
WHT rate by category × payment amount	Per ITL Art. 68	Should equal WHT remitted
Sum of monthly WHT returns	sa-withholding-tax	Must equal WHT due
Late WHT filing penalty risk	1% per month + tax penalty per ZATCA penalty regime	Flag for reviewer

Cross-check 4 — VAT reconciliation

Source	Figure	Rule
Annual output VAT	Sum of period returns	Anchor
15% (standard rate from 1 July 2020) × VAT-able sales	Computed	Reconciles
Annual input VAT	Sum of period returns	Per saudi-arabia-vat
Zero-rated exports	Per saudi-arabia-vat	Disclosed separately
Exempt sales (financial services, residential rent etc.)	Per saudi-arabia-vat	Disclosed separately

Cross-check 5 — RETT (if any disposals)

Source	Figure	Rule
Real estate disposals during the year	Per sa-rett	Anchor
5% × disposal value	Should equal RETT paid at notarisation	RETT-1 form
VAT exemption confirmation	Real estate disposals are VAT-exempt (RETT replaces VAT on real estate from October 2020)	Disclosure check

Cross-check 6 — Excise (if any)

Source	Figure	Rule
Bi-monthly excise returns	Per sa-excise-tax	Anchor
Annual excise tax collected + paid	Sum of bi-monthly returns	Reconcile
Excise-able goods register	Per sa-excise-tax	Tobacco 100% / soft drinks 50% / energy drinks 100% / sweetened beverages 50% / e-cigarettes 100%

Cross-check 7 — E-Invoicing (Fatoorah)

Source	Figure	Rule
Phase 1 generation (since 4 December 2021)	All B2B and B2C invoices generated electronically	Compliance check
Phase 2 integration with ZATCA (rolled out in waves)	If wave is in scope, integration confirmed	Compliance check; if not yet in wave, note expected wave
QR code on each invoice	Mandatory	Spot-check sample

Cross-check 8 — Working capital / Zakat adjustments

Source	Figure	Rule
Long-term liabilities (added to Zakat base)	Per sa-zakat	Anchor
Long-term assets (deducted from Zakat base)	Per sa-zakat	Anchor
Inventory financed by short-term borrowing	Per sa-zakat	Adjustment per Implementing Regulations
Provisions for doubtful debts	Per sa-zakat	Add-back rules per Implementing Regulations

• Cross-check 9 — Tolerance discipline — For Zakat / CIT base computation: SAR 100 default tolerance. For larger entities (> SAR 40M revenue): SAR 1,000 tolerance. Discrepancies between SAR 100 and SAR 10,000 — flag and proceed. Above SAR 10,000 — raise as "Needs Input" before sign-off.

Section 5 — Tax computation summary (Zakat / CIT / Mixed bottom line)

The bottom line of the return appears in the reviewer brief executive summary.

5.1 Zakat declaration bottom line (Saudi/GCC-owned)

• Zakat declaration bottom line formula — Equity (capital + retained earnings + reserves) SAR X Plus: Long-term liabilities SAR X Plus: Provisions added back SAR X Less: Long-term assets SAR X Less: Other deductible items per Implementing Regulations SAR X = Zakat base SAR X Apply 2.5% (Gregorian year) or 2.577% (Hijri year) SAR X = Zakat liability SAR X Less: Any advance Zakat paid SAR X = Net Zakat payable SAR X

5.2 CIT return bottom line (foreign-owned)

• CIT return bottom line formula — Accounting profit before tax SAR X Plus: Tax adjustments (non-deductible) SAR X Less: Tax adjustments (extra-deductible) SAR X = Taxable income SAR X Interest deduction limit: 50% of EBITDA — apply if breached SAR X Loss carry-forward (25% cap per year) SAR X = Final taxable income SAR X CIT at 20% (general) / 85% (upstream petroleum) / 30% (natural gas) SAR X = CIT liability SAR X Less: Foreign tax credit (treaty-based) SAR X Less: Any WHT credit (rare for resident filer) SAR X Less: Any advance CIT paid SAR X = Net CIT payable SAR X

5.3 Mixed-entity bottom line

• Mixed-entity bottom line formula — Zakat base × Saudi/GCC% × 2.5% SAR X (Zakat portion) Taxable income × foreign% × 20% (or applicable) SAR X (CIT portion) Combined liability on single return SAR X

5.4 Refund treatment

• Refund treatment rule — If net is refundable: claim is made on the ZATCA portal. Refunds are processed under the Tax Procedures Law; typical processing time 30–60 days, longer if ZATCA selects for audit. If net is payable: must be settled via SADAD billing before the 120-day deadline (see Section 6). (Tax Procedures Law)

Section 6 — Payment instructions — ZATCA portal, SADAD billing

All Saudi tax payments flow through the ZATCA portal → SADAD billing mechanism.

6.1 The ZATCA → SADAD flow

• ZATCA to SADAD flow steps — 1. Log into ZATCA portal at https://zatca.gov.sa with TIN + password (or via Nafath / national IAM) 2. Navigate to "Returns and Payments" → select the relevant return (Zakat / CIT / VAT / WHT / Excise) 3. Submit the return — the portal computes the liability based on entries; verify against the working paper 4. Generate SADAD bill — ZATCA issues a SADAD billing ID (numeric, typically 14 digits or as currently formatted) 5. Pay via Saudi bank channel — present the SADAD billing ID via: Internet banking — every Saudi bank has a SADAD payment tab; select biller "ZATCA" / "Zakat, Tax and Customs Authority" → enter billing ID → pay; Mobile banking app — same flow; SADAD-enabled ATM — select SADAD payments → ZATCA → enter billing ID; Bank branch teller — present billing ID for over-the-counter payment 6. Payment receipt — bank issues a SADAD payment confirmation; the payment auto-feeds to ZATCA's records against the TIN 7. Verify in ZATCA portal — payment status updates from "Pending" to "Paid"

6.2 Common tax heads / SADAD bill mapping

Common tax heads / SADAD bill mapping table

Tax head	ZATCA portal section	Periodicity	Used for
Zakat	Annual Zakat declaration	Annual (120 days from FYE)	Saudi/GCC entities
Corporate Income Tax	Annual CIT (Form 800)	Annual (120 days from FYE)	Foreign-owned entities
Mixed Zakat + CIT	Annual combined	Annual (120 days from FYE)	Mixed-ownership entities
VAT	Monthly or quarterly	28th of following month	All VAT-registered
Withholding Tax	Monthly	Within 10 days of month-end	All WHT agents
Excise Tax	Bi-monthly	Within 15 days of period-end	Excise-able goods
RETT	Transaction-by-transaction	At notarisation	Real estate disposers

6.3 Payment timing relative to filing

Payment timing relative to filing table

Payment	Due date	Filing reference
Annual Zakat / CIT balance	Within 120 days of FYE (for 31 Dec FYE → 30 April 2026)	Annual return
Monthly VAT (turnover > SAR 40M)	28th of following month	VAT return
Quarterly VAT (turnover ≤ SAR 40M)	28th of month following quarter	VAT return
Monthly WHT	Within 10 days of month-end	WHT return
Bi-monthly Excise	Within 15 days of period-end	Excise return
RETT	At notarisation	Transactional

• Payment settlement rule — The SADAD billing payment must be settled by the deadline. The annual return submission and the payment can be done in the same session via the portal.

6.4 Penalties for late payment / filing

Penalties for late payment / filing table

Item	Penalty	Source
Late payment of any tax (Zakat / CIT / VAT / WHT / Excise)	1% of unpaid amount per month (or part of month)	Tax Procedures Law and Zakat Implementing Regulations
Late filing of annual return	5%–25% of tax due depending on delay band	Tax Procedures Law
Late VAT return	5%–25% of VAT due	VAT Implementing Regulations
Late WHT remittance	1% per month plus penalty 1%–25%	ITL Implementing Regulations
False declaration / evasion	Up to 25% of underpaid amount plus criminal exposure under Anti-Evasion provisions	Tax Procedures Law

Section 7 — Filing instructions — annual return within 120 days of FYE via ZATCA

7.1 Filing channel

• Filing channel rule — All Saudi annual tax filings are submitted electronically through the ZATCA portal at https://zatca.gov.sa. Paper filings are not accepted for normal taxpayers.

7.2 Submission steps

• Submission steps — 1. Confirm CR / TIN validity — both must be active in MoC and ZATCA records 2. Prepare audited financial statements if required (entities above SAR 40M revenue typically must attach audited FS signed by a SOCPA-licensed auditor) 3. Log into ZATCA portal with TIN + password / Nafath 4. Navigate to "Returns and Payments" → select "Annual Zakat/Tax Return" 5. Choose the form: Zakat declaration form (for Saudi/GCC); CIT Form 800 series (for foreign-owned); Combined declaration (for mixed) 6. Enter the computation using the working paper as source 7. Upload attachments: Audited financial statements (SOCPA-signed); Auditor's report; Cap table at FYE (mixed entities); Supporting schedules as required 8. Validate — portal runs arithmetic and schema checks; resolve errors 9. Submit — receive ZATCA acknowledgement with submission reference and timestamp 10. Generate SADAD bill for payable amount 11. Pay via Saudi bank channel (per Section 6) 12. Save acknowledgement and SADAD payment confirmation — legal proof of filing and payment

7.3 Deadlines (illustrative — adjust to actual FYE)

Deadlines table

Fiscal year-end	120-day deadline	Notes
31 December 2025	30 April 2026	Most common Gregorian filers
31 March 2026	29 July 2026	Some entities
30 June 2026	28 October 2026	Hijri-aligned filers
30 September 2026	28 January 2027	Some entities
Custom year-end approved by ZATCA	FYE + 120 days	Per approval

• Hijri filer conversion — For Hijri-year filers, the 120 days runs from the Hijri year-end and is converted to Gregorian for portal submission.

7.4 Extension of time

Extension of time table

Item	Mechanism
Extension request	Application to ZATCA before deadline, citing grounds (typically audit delay or major operational disruption)
Typical extension	30 days; rarely more
Penalty during extension	Late payment penalty (1% per month) still accrues unless ZATCA grants a payment moratorium

7.5 Audit & assessment

ZATCA may select returns for audit within 5 years of filing (per Tax Procedures Law). Triggers include:

• Significant book-to-tax adjustments
• Loss carry-forward usage
• Related-party transactions (transfer pricing — Saudi adopts OECD-aligned TP rules; Local File / Master File / CbCR thresholds apply)
• Refund claims
• Industry-specific risk profiling

Section 8 — WPS + Saudization compliance check

This section is critical because ZATCA increasingly cross-references labor compliance with tax filings, and Yellow/Red Nitaqat tier is flagged on the entity's file.

8.1 WPS (Wage Protection System) via Mudad

• WPS via Mudad requirements — Every entity with employees must: Submit monthly WPS file via the Mudad platform (https://mudad.com.sa); Confirm all employees received salary via authorised bank channel; Submit no later than the salary disbursement deadline (typically 3 days after the salary date). Capstone check: Confirm 12 monthly WPS files were submitted for the year. If any gap, flag as a "Reviewer Attention" item — gaps in WPS are a compliance violation under Ministry of Human Resources and Social Development (MHRSD) regulations and can result in: - Visa block on the company - Suspension of work permit renewals - Civil penalties

8.2 Saudization — Nitaqat tier

The Nitaqat program tracks Saudi national employment as a percentage of total workforce. Tiers (current framework):

Nitaqat tier table

Tier	Status	Implications
Platinum	Best	Maximum benefits; expedited services
High Green	High compliance	Normal services; favoured for govt contracts
Medium Green	Compliant	Normal services
Low Green	Compliant but marginal	Normal services; warning zone
Yellow	Non-compliant	Visa restrictions; cannot renew certain work permits
Red	Severely non-compliant	Severe visa/work permit restrictions; major risk for operations

• Capstone Nitaqat check — Capstone check: Confirm Nitaqat tier per sa-gosi-saudization. If Yellow or Red, raise as a "Reviewer Attention" item — does not block the tax filing but is a major operational risk.

8.3 GOSI confirmation

• GOSI confirmation checks — Confirm GOSI monthly contributions paid for all 12 months; Confirm employee numbers reconcile to financial statement salary expense; Saudi nationals: employer contribution 11.75% (current rates — verify at filing time); employee 9.75%; unemployment insurance (SANED) 1%/1%; Non-Saudi: employer occupational hazard only — 2% (current rate — verify)

8.4 Attestation block

The reviewer brief must include:

[ ] All 12 monthly WPS files submitted via Mudad
[ ] All 12 monthly GOSI returns filed and paid
[ ] Nitaqat tier confirmed as: ______________
[ ] No outstanding labor violations flagged with MHRSD
[ ] Employee count reconciles to financial statements

Section 9 — Year-end planning notes

9.1 Zakat working capital optimisation (Saudi/GCC entities)

• Zakat working capital planning — The Zakat base under the equity method includes: Long-term liabilities (added); Long-term assets (deducted). Strategic planning at FYE: Accelerate qualifying long-term asset purchases before FYE to reduce Zakat base; Convert short-term debt to long-term (over 1 year) to add to Zakat base — but watch other consequences; Time inventory write-downs and provisions per Implementing Regulations; Consider Zakat-on-profit method comparison — whichever is lower applies

9.2 CIT interest deduction limit (foreign entities)

• Interest deduction limit planning — ITL Article 12 / Implementing Regulations cap interest deduction at 50% of EBITDA. Planning items: Forecast EBITDA and interest expense before FYE; Consider thin-cap restructuring if interest exceeds the cap; Carry-forward of denied interest: verify current rules in sa-corporate-tax (ITL Article 12)

9.3 WHT exemption certificates

• WHT exemption certificate planning — For payments to non-residents in treaty countries (Saudi Arabia has 50+ DTAs): Apply for WHT exemption / reduced rate certificate before payment; ZATCA processes certificate applications via the portal; Without certificate, full statutory WHT applies; refund claim possible but cash-tied-up for months

9.4 Saudization workforce planning

Plan Nitaqat tier maintenance for 2026: hire Saudi nationals, train, retain; Use programs like HRDF / HADAF subsidies for Saudi training; Forecast Saudi national % by quarter to avoid tier drop

9.5 VAT periodicity transition

If turnover crosses SAR 40M threshold, periodicity becomes mandatory monthly. Plan: Internal controls upgrade for monthly close; Reconciliation cadence; E-invoicing Phase 2 wave inclusion check

9.6 E-Invoicing Phase 2 waves

ZATCA continues to phase in Phase 2 integration in waves. Each wave is announced by ZATCA with a target date. Confirm: Has the entity received the wave notification? Is integration with ZATCA infrastructure complete? Is the entity exchanging cryptographic stamps / UUIDs correctly?

9.7 RETT planning

• RETT planning — If real estate disposals are planned in 2026: RETT 5% on disposal value, paid at notarisation; RETT replaced VAT on real estate from 4 October 2020; Some exemptions (gifts between first-degree relatives, certain inheritance, etc.) — verify per sa-rett

9.8 Transfer pricing / BEPS

• Transfer pricing / BEPS thresholds — Saudi adopted OECD-aligned TP rules; entities meeting thresholds must prepare: Local File; Master File; Country-by-Country Report (CbCR) — for MNEs above SAR 3.2 billion consolidated revenue. Not assembled here; reference via sa-corporate-tax.

Section 10 — Reviewer attestation block

The reviewer brief contains an attestation block:

# Reviewer Attestation — [Entity Name] — FY 2025

Reviewer name: ____________________________________
Membership body: [ ] SOCPA   [ ] ICAEW   [ ] ACCA   [ ] US CPA practising in KSA
Membership number: ____________________________________
Date of review: ____________________________________

I have reviewed:
[ ] Zakat base computation per sa-zakat (Saudi/GCC entities)
[ ] CIT computation per sa-corporate-tax (foreign-owned entities)
[ ] Mixed-entity apportionment (where applicable)
[ ] Withholding tax compliance per sa-withholding-tax with SADAD billing verification
[ ] VAT reconciliation per saudi-arabia-vat
[ ] GOSI & Saudization compliance per sa-gosi-saudization
[ ] WPS file submissions via Mudad (12 monthly files confirmed)
[ ] Nitaqat tier confirmed (not Yellow / Red)
[ ] RETT disclosures per sa-rett (where applicable)
[ ] Excise reconciliation per sa-excise-tax (where applicable)
[ ] E-Invoicing (Fatoorah) Phase 1 + Phase 2 compliance per saudi-einvoice
[ ] Entity records per sa-formation
[ ] Cross-skill reconciliations within tolerance
[ ] All positions taken have legislative citations (ITL / Zakat IR / VAT IR / RETT)
[ ] Audited financial statements attached (where threshold met)

Sign-off: ____________________________________

I confirm the return is ready for ZATCA submission and that the taxpayer / authorised representative has been provided with the action list and SADAD billing register.

Section 11 — Final taxpayer action list template

# Action List — [Entity Name] — FY 2025 (Saudi Arabia)

## Immediate (before 120-day deadline — i.e. by [deadline date])

### Annual return submission
1. Log into ZATCA portal with TIN + password / Nafath
2. Open "Annual Zakat/Tax Return" → select form (Zakat / CIT / Mixed)
3. Enter computation values from working paper
4. Upload audited financial statements (SOCPA-signed) and supporting schedules
5. Submit return → save acknowledgement with submission reference and timestamp
6. Generate SADAD bill for the payable amount
7. Pay via Saudi bank (internet banking, mobile app, SADAD ATM, or branch teller)
8. Save SADAD payment confirmation
9. Verify "Paid" status in ZATCA portal within 1–2 business days

### Final WHT remittance (if year-end month outstanding)
1. Confirm all 12 monthly WHT returns filed (within 10 days of month-end each)
2. Confirm SADAD bills paid for each month

### Final VAT remittance (if year-end period outstanding)
1. Confirm all VAT periods (monthly or quarterly) filed and paid
2. Verify "Paid" status for each period

### Excise reconciliation (if applicable)
1. Confirm all bi-monthly excise returns filed and paid

Monthly / periodic compliance through FY 2026

Monthly / periodic compliance through FY 2026 table

Item	Tax head	Due
WHT — payments to non-residents	Monthly WHT return	Within 10 days of month-end
VAT (monthly filer — turnover > SAR 40M)	VAT return	28th of following month
VAT (quarterly filer)	VAT return	28th of month following quarter
GOSI monthly contribution	GOSI portal	Around the 15th — verify
WPS file via Mudad	Mudad platform	After each salary disbursement (typically 3 days)
Excise bi-monthly	Excise return	Within 15 days of period-end
RETT	Per transaction	At notarisation

Record retention

• Record retention rule — Per Tax Procedures Law and Zakat Implementing Regulations, records must be retained for 6 years from end of the relevant tax year (longer if assessment is open). Records include: Books of account (general ledger, sales register, purchase register); SADAD payment confirmations; ZATCA submission acknowledgements; VAT invoices (Fatoorah-compliant, with QR code); WHT certificates issued to non-residents; GOSI monthly returns and confirmations; WPS monthly files; Bank statements; Audited financial statements and auditor's reports; Cap table updates (mixed entities). Records must be retrievable in Arabic where ZATCA requests (some documents may be in English with Arabic translation on request). (Tax Procedures Law and Zakat Implementing Regulations)

Compliance attestations to keep current

• CR renewal (annually, via MoC)
• VAT registration active
• GOSI employer registration active
• Mudad subscription active
• Saudization Nitaqat tier maintained at Medium Green or above
• E-Invoicing Phase 2 integration current

Section 12 — Refusals

• R-SA-ASM-1 — Upstream skill did not run. Name the missing skill. Continue with available data; flag the gap; do not fabricate the missing computation.
• R-SA-ASM-2 — Upstream self-check failed. Note the specific check; continue but flag.
• R-SA-ASM-3 — Cross-skill reconciliation > SAR 10,000. Raise as "Needs Input"; do not silently round.
• R-SA-ASM-4 — Out of scope: upstream petroleum (Aramco-style 85% rate regime), natural gas investment (30%–85% bands), banking under SAMA-regulated specialised regimes, insurance specialised regimes, listed Tadawul-specific reporting requirements beyond the standard ownership split, qualified investment funds (QIFs) under special regimes, Real Estate Investment Traded Funds (REITs) under specialised CMA rules, Special Economic Zones (Riyadh ITSEZ, Jazan, Ras Al-Khair, Cloud Computing Special Economic Zone, Special Integrated Logistics Zone), Regional Headquarters (RHQ) tax incentive regime, and entities in NEOM / Red Sea Global / Qiddiya with specialised arrangements. Flag for human specialist; do not attempt.
• R-SA-ASM-5 — Out of scope: PE-only filings for non-resident contractors operating without local CR; pure-play offshore service permanent establishments under treaty-protected positions; transfer pricing assessments for MNEs above CbCR threshold (handled via sa-corporate-tax with specialist support); APA negotiations with ZATCA. Refer to a specialist.
• R-SA-ASM-6 — Intake incomplete. Name the missing intake field (CR, TIN, VAT number, ownership split, fiscal year-end, audited FS, GOSI ID, Mudad subscription). Cannot finalise the return until provided.
• R-SA-ASM-7 — Asked to submit to ZATCA. This skill produces a working paper. Submission is the taxpayer's (or their authorised representative's) action, after credentialed reviewer sign-off. Decline politely; provide the filing instructions instead.
• R-SA-ASM-8 — Asked to confirm rates / thresholds without verification against current ZATCA regulations. Defer to sa-zakat / sa-corporate-tax / saudi-arabia-vat which carry the verified current-period figures. Flag any figure used here as "verify against current upstream skill output".
• R-SA-ASM-9 — Asked to opine on Sharia compliance of Zakat base treatment. Decline — Sharia interpretation is the role of the entity's Sharia board or qualified scholar; the capstone applies ZATCA's Implementing Regulations as published, not independent Sharia analysis.

Section 13 — Self-checks

All upstream skills required for the chosen return type have produced output, or the gap is flagged.

Ownership split is correctly classified between Saudi/GCC and foreign for mixed entities, with cap table support.

Zakat base (equity method) reconciles to the financial statements equity section; long-term liabilities and long-term assets correctly identified.

CIT taxable income reconciles from accounting profit through documented tax adjustments with ITL section references.

Interest deduction limit (50% of EBITDA per ITL Art. 12) is tested and applied if breached.

All 12 monthly WHT returns are confirmed filed; each has a SADAD billing ID and payment confirmation.

VAT reconciliation: annual revenue ties to sum of monthly/quarterly VAT returns ± documented reconciling items.

All 12 monthly WPS files via Mudad are confirmed submitted.

Nitaqat tier is identified; if Yellow or Red, raised as a Reviewer Attention item.

Audited financial statements are attached where threshold met (SAR 40M+ revenue or other ZATCA-specified threshold).

RETT disclosures are present for any real estate disposals during the year.

Excise reconciliation is present if entity deals in excise-able goods.

Fatoorah (e-invoicing) Phase 1 compliance confirmed; Phase 2 integration confirmed where wave applies.

120-day deadline is explicitly stated in the action list with the correct calendar date computed from FYE.

SADAD billing register lists every payable item with billing ID, amount, and payment status.

Record retention period (6 years per Tax Procedures Law) is stated in the action list.

Reviewer brief contains legislation citations (Royal Decree numbers, ITL articles, Zakat IR articles, VAT IR articles, RETT framework) for every position taken.

Credentialed reviewer (SOCPA / ICAEW / ACCA / US CPA) sign-off requirement is stated in the executive summary, attestation block, and action list.

For mixed entities, Saudi/GCC% × Zakat base × 2.5% PLUS foreign% × taxable income × applicable CIT rate equals the combined liability on the return.

WHT rates applied per ITL Art. 68 (5% royalties / 15% management / 20% other / 5% dividends / 5% interest / 5% rent / 5% technical services — confirm against current upstream).

Section 14 — Output files

The final output is three files:

1. [entity_slug]_FY2025_sa_master.xlsx — Master workbook. Sheets per Section 4.1. Use live formulas where possible; verify no #REF! errors.

2. reviewer_brief.md — Markdown file with executive summary, computation walk-through, cross-check results, positions taken, attention flags, attestation block.

3. taxpayer_action_list.md — Markdown file with all Section 11 contents.

All three files are placed in /mnt/user-data/outputs/ and presented to the user at the end.

If execution runs out of context mid-build, complete the computation work first and produce whichever formatted outputs are finished, then state clearly which deliverables are partial.

Section 15 — Known gaps

1. PDF form filling is not automated; the reviewer or taxpayer enters values into the ZATCA portal using the working paper.
2. ZATCA XML / API submission is not produced by this skill; integrations with ERP / e-invoicing solution providers handle that.
3. Auditor's report attachment is the taxpayer's responsibility; this skill flags audit requirement based on revenue threshold but does not produce the audit itself.
4. Transfer pricing Local File / Master File / CbCR content is referenced via sa-corporate-tax but not assembled here.
5. Treaty-based WHT reductions are referenced via sa-withholding-tax but specific DTA analysis is upstream.
6. Special regimes (Aramco upstream petroleum, natural gas investment, banking, insurance, SEZ, RHQ, NEOM, Red Sea Global, Qiddiya) are out of scope.
7. Sharia-board specific interpretations of Zakat base are out of scope; the capstone applies ZATCA Implementing Regulations as published.
8. Hijri-year conversions are handled by sa-zakat; the capstone uses the upstream output as-is.
9. Local labor compliance beyond WPS / Nitaqat (e.g., specific MHRSD inspections) is out of scope.
10. Customs duty interactions on imports / exports are out of scope; ZATCA merged with Saudi Customs in 2021 but the Customs Schedule is administered separately.

Change log

• v1.0 (May 2026): Initial release. Modelled on pk-return-assembly and us-ca-return-assembly, adapted for Saudi annual returns, ZATCA portal filing, SADAD billing payment flow, the Zakat / CIT / mixed-entity split, WPS + Saudization compliance integration, and Royal Decree-based statutory references. Coordinates nine upstream Saudi skills.

Section 16 — Sources

Sources table

Source	Reference
Income Tax Law (ITL)	Royal Decree No. M/1 of 1425 AH (15 January 2004) and successive amendments; articles referenced throughout (Arts. 1–5, 12, 13, 27, 30, 68, 71, 72)
ITL Implementing Regulations	Issued by Ministerial Resolution; defines tax adjustments, depreciation, interest deduction limit, loss carry-forward, WHT mechanism
Zakat — Royal Decree	Royal Decree No. M/40 of 1405 AH and successor regulations
Zakat Collection Implementing Regulations	Issued by ZATCA; equity-method base, Zakat-on-profit method, working capital adjustments
VAT Law	Royal Decree No. M/113 of 1438 AH (4 November 2017); VAT Implementing Regulations issued by ZATCA
Excise Tax Law	Royal Decree No. M/86 of 1438 AH (29 May 2017); Excise Implementing Regulations
Real Estate Transaction Tax (RETT)	Royal Decree No. M/84 of 14/02/1442 AH (effective 4 October 2020); RETT Implementing Regulations
Tax Procedures Law	Common procedural framework for ZATCA-administered taxes; penalties, deadlines, assessment, appeals
E-Invoicing (Fatoorah)	ZATCA Resolution; Phase 1 effective 4 December 2021; Phase 2 phased waves from 2023 onward
GOSI — Social Insurance Law	Royal Decree No. M/22 of 1389 AH and amendments
Saudization (Nitaqat)	Ministry of Human Resources and Social Development decisions
WPS — Wage Protection System	MHRSD regulations via Mudad platform
Companies Law	Royal Decree No. M/132 of 1443 AH (effective 19 January 2023, replacing 1965 Companies Law) — for entity structure, audit thresholds
ZATCA portal	https://zatca.gov.sa
Mudad portal	https://mudad.com.sa
GOSI portal	https://www.gosi.gov.sa
SOCPA — Saudi Organization for Chartered Public Accountants	https://socpa.org.sa
Ministry of Commerce (MoC) — CR registry	https://mc.gov.sa
Ministry of Human Resources and Social Development (MHRSD)	https://hrsd.gov.sa
SADAD payment system	National bill-payment infrastructure operated by Saudi Central Bank (SAMA)
Skill version	1.0

Footer disclaimer

OpenAccountants — open-source accounting skills for AI This is not tax advice. All outputs must be reviewed and signed off by a credentialed reviewer (SOCPA member, or recognised ICAEW / ACCA / US CPA practising in KSA) before filing via the ZATCA portal.

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