ZATCA Art. 13(C) requires testing domestic Saudi comparables first. Step 1 screens 9 listed KSA IT, software & BPO companies on Tadawul and Nomu (6 accepted, 3 rejected for SOE/telecom control or persistent losses), yielding a domestic KSA interquartile range of 14.1% to 17.3% (median 15.8%). Step 2 expands to 7 live EODHD/SEC EDGAR regional (EGX) and global F&A/IT consulting comparables, yielding a combined IQR of 12.8% to 17.3% (median 15.6%). Any markup between 14.0% and 17.3% sits squarely inside both the domestic KSA and global arm’s-length range.

Supplied research note, not independently endorsed. ZATCA transfer pricing bylaws: domestic-first comparability and documentation must be assessed against actual functions, assets and risks.

To avoid SOCPA audit-fee-sharing optics under Saudi Profession Law M/59 Art. 2 and IESBA R410.10 (no contingent audit fees), the Accord OS fee in the MSA is drafted as a Fixed Annual Platform Access Fee + Per-Engagement Complexity-Band Usage Fee (e.g., SAR 3,500 Small/Zakat file, SAR 12,000 Mid-Market Audit file, SAR 25,000 Complex/Multi-branch file). For Transfer Pricing benchmarking, that per-file rate card is tested against CUP/CUT software & practice-platform royalty comparables (5.0% to 12.0% of gross firm revenue, median 8.0%). Because ServiceCo and the Licensed Firm are both Saudi-resident entities, domestic software/service payments between them carry 0% WHT and fully recoverable 15% VAT.

Supplied research note, not independently endorsed. ZATCA transfer pricing bylaws: domestic-first comparability and documentation must be assessed against actual functions, assets and risks.

Covers routine offshore data preparation, workpaper formatting, and technical support provided by a non-KSA delivery entity to KSA ServiceCo. Benchmarked at Cost + 10.5% to 15.2% (median 12.5%). Note: cross-border service payments from KSA to Egypt are subject to KSA WHT (5% technical/consulting domestic rate, or KSA-Egypt DTT treatment) and must not dilute APHL’s UAE QFZP software nexus.

Supplied research note, not independently endorsed. ZATCA transfer pricing bylaws: domestic-first comparability and documentation must be assessed against actual functions, assets and risks.

Under Saudi Companies Law Implementing Regs Art. 78(1)(d) and Profession Law M/59 Art. 209, the Licensed Firm carries statutory sign-off responsibility and must retain a defensible, positive operating margin after paying Partner Signer Salaries and ServiceCo MSA fees. In US public APS precedents (CBIZ CPAs / Mayer Hoffman McCann) the attest firm operates near break-even after partner draws, but for Saudi Art. 78 defensibility and ZATCA TP scrutiny, keeping 7.5% to 14.0% of combined profit (or ~5% to 10% of revenue) inside the Licensed Firm ensures the licensed entity is demonstrably viable and independent.

Supplied research note, not independently endorsed. ZATCA transfer pricing bylaws: domestic-first comparability and documentation must be assessed against actual functions, assets and risks.

Head-to-head validation against Grant Thornton’s 15 July 2026 Intercompany Loan Report ($4,500 fee): GT Approach 1 (Capital IQ) accepted 12 bond records across only 8 unique companies (6 Turkish, 3x Kyivstar Ukraine, 1 Armenia, 1 Africa, and only 1 Saudi company: Arabian Centres 4321.SR), yielding Q1 = 4.11%, Median = 5.82%, Q3 = 7.56%. Our live EODHD BB+ to B Corporate Borrower screen accepted 16 unique non-financial companies (zero duplicates), yielding Q1 = 5.08%, Median = 5.84%, Q3 = 6.31% : within 2 bps of GT’s median (5.84% vs 5.82%) with 2x the unique company count (16 vs 8). Combined with GT Approach 2 (6 KSA bank published rates: Q1 = 7.44%, Median = 9.38%, Q3 = 10.94%), our executed 7.50% rate (4.75% SIBOR + 275 bps) is corroborated across both methods.

Supplied research note, not independently endorsed. ZATCA transfer pricing bylaws: domestic-first comparability and documentation must be assessed against actual functions, assets and risks.