English text status

English translation published by the Legislation and Legal Opinion Commission. The Arabic text published in the Official Gazette remains the legal reference in the event of any discrepancy.

Practical summary

Market Value replaces the agreed value for a Supply between Related Persons only when both conditions are met: the agreed value is below Market Value and the customer cannot deduct Input Tax in full.

Who should read this?

Groups, Related Persons and internal-pricing, finance and tax teams.

Why does it matter?

A relationship alone does not trigger Market Value. Both conditions must coexist; where they do, the VAT base may exceed the contract or invoice price.

Two cumulative conditionsRelated PersonsMarket Value

Current text

Notwithstanding the provisions of Articles 20 and 21 of this Law, the value of a Supply of Goods or Services between Related Persons shall be calculated on the basis of the Market Value if the value of Supply is less than the Market Value and the Customer is not entitled to deduct the Input Tax in full. The Regulations shall specify the terms and controls necessary for the application of this Article.

Must the agreed value be replaced?

  1. 1

    Confirm the parties are Related Persons under the statutory definition.

  2. 2

    Compare the agreed value with Market Value at the transaction date.

  3. 3

    Determine whether the customer has a full Input Tax deduction right.

  4. 4

    Retain valuation evidence and be ready to provide it within 30 days if requested.

Connected provisions

Official guides and tools

Illustrative example by Madar

Below-market sale to a related company

If an asset is sold to a Related Person for 60 when Market Value is 100, the base does not automatically become 100. The customer's inability to deduct Input Tax in full must also be established.

Questions to help you apply it

  • Are the parties Related Persons?
  • Is the agreed value below Market Value?
  • Can the customer deduct Input Tax in full?