Corporate taxpayers in Saudi Arabia often face situations where they disagree with a tax assessment issued by the Zakat, Tax and Customs Authority (ZATCA). The law provides clear procedures for filing an objection or appeal to ensure fairness, transparency, and the right to be heard. This guide explains the process, timelines, and strategies for effectively challenging an assessment.
📜 Understanding ZATCA Assessments
A ZATCA assessment is an official determination of the amount of tax or zakat payable for a given tax period. Assessments may be issued due to:
- Discrepancies found in filed returns.
- Audit adjustments based on supporting documentation.
- Non-filing or late filing of returns.
- Differences arising from withholding tax, VAT, or zakat calculations.
⏳ Timeframe for Filing an Objection
Under Saudi tax law, a taxpayer has 60 days from the date of notification of the assessment to file an objection with ZATCA. Missing this deadline can result in the assessment becoming final and enforceable.
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🛠 Step-by-Step Process for Filing an Objection
- Log in to ZATCA’s e-Services Portal using your taxpayer credentials.
- Navigate to the Objections section under the relevant tax type (Corporate Income Tax, Zakat, VAT, etc.).
- Review the assessment details and select the option to File Objection.
- Upload supporting documents, such as financial statements, contracts, and reconciliations.
- Provide a clear explanation of why you disagree with the assessment, citing legal provisions where possible.
- Submit electronically and retain proof of submission.
⚖️ Escalation to the Appeal Stage
If ZATCA rejects the objection, you have the right to escalate the matter to the General Secretariat of Tax Committees (GSTC) within 30 days of the decision. The appeal process involves:
- Filing a formal appeal through GSTC’s online portal.
- Submitting legal arguments, evidence, and expert opinions.
- Attending hearings if required.
📌 Best Practices for a Successful Objection or Appeal
- Engage a Saudi tax advisor familiar with ZATCA’s internal procedures.
- Submit comprehensive documentation and evidence.
- Reference relevant laws, regulations, and double tax treaties.
- Maintain professional and factual communication with ZATCA.
⚠️ Risks of Ignoring an Assessment
- Automatic enforcement of the assessed amount.
- Penalties for late payment or non-compliance.
- Restriction on customs clearance and other ZATCA services.
🏁 Conclusion
Filing an objection or appeal after receiving a ZATCA assessment is a structured process that requires careful preparation, legal awareness, and timely action. Corporate taxpayers in Saudi Arabia can protect their interests by acting within deadlines and presenting strong factual and legal arguments.