Carryforward of Net Operating Losses (NOLs) in Saudi Arabia: Understanding the 25% Profit Offset Limit

In Saudi Arabia, corporate taxpayers can carry forward Net Operating Losses (NOLs) to reduce taxable income in future years. However, under ZATCA’s tax rules, the offset is limited to 25% of annual taxable profit for each year. This blog explains the NOL carryforward rules, calculation methods, strategic uses, and compliance requirements for businesses operating in the Kingdom.

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What are Net Operating Losses?

A Net Operating Loss occurs when a company’s allowable tax deductions exceed its taxable income in a given year. In Saudi Arabia, NOLs cannot be carried back to prior years but can be carried forward indefinitely, subject to a 25% profit offset cap.

The 25% Profit Offset Rule

For each future year in which a company earns taxable profits, only up to 25% of that year’s taxable profit can be reduced by carried-forward NOLs. This rule ensures that companies continue to contribute to tax revenues even if they have significant accumulated losses.

Example Calculation

Year Taxable Profit (SAR) Max NOL Offset (25%) Remaining NOL Balance
2025 8,000,000 2,000,000 18,000,000
2026 12,000,000 3,000,000 15,000,000

Key Compliance Requirements

  • Track NOL balances accurately year by year.
  • Maintain supporting documents for the original loss years.
  • Apply the 25% cap strictly to avoid penalties from ZATCA.
  • Declare NOL application in the annual corporate income tax return.

Strategic Use of NOLs

  • Plan the timing of asset disposals and major income events to maximize NOL utilization.
  • Consider group restructuring or mergers to potentially leverage NOLs across related entities (subject to ZATCA rules).
  • Review contracts for long-term projects to match profit recognition with available NOLs.

Common Pitfalls

  • Failing to keep adequate proof of losses in the original year.
  • Applying offsets to more than 25% of taxable profits, triggering reassessment.
  • Overlooking NOL expiration risks when laws change.

Understanding and applying the 25% profit offset limit is essential for Saudi corporate taxpayers aiming to optimize tax efficiency while remaining compliant. Proper tracking, strategic planning, and professional advice can ensure NOLs remain a valuable long-term tax asset.

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