The guidance outlines when VAT responsibility shifts to electronic marketplaces, impacting reporting and operations. Deemed supplier status applies to non-resident electronic services and resident non-registered suppliers. Obligations include VAT invoicing and returns. Key exceptions exist, but operational involvement influences VAT responsibilities, especially for food delivery and accommodation platforms.
New VAT Deemed Supplier Rules for Electronic Marketplaces in Saudi Arabia from Jan 2026
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Author: Ema Stamenković
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General information
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1084
Content accuracy validation date:
24.02.2026
Content accuracy validation time:
09:12h
The guidance clarifies when VAT responsibility shifts from sellers to electronic marketplaces, requiring some platforms to account for VAT themselves instead of leaving it to individual suppliers. This affects where VAT is reported and requires marketplaces to review their arrangement structures and operations.
Key Highlights
- Deemed Supplier Status applies when a marketplace facilitates:
- Electronic services supplied by non-residents, or
- Goods/services supplied by resident non-registered suppliers (effective from 2026).
- Exceptions: A marketplace is not deemed a supplier if:
- The underlying supplier is clearly identified,
- Contracts are made directly between supplier and customer, and
- The marketplace does not control terms, pricing, payment, or complaints handling.
- Not Facilitating a Supply: Activities limited to payment processing, advertising, or redirecting customers do not trigger deemed supplier status.
- Obligations of deemed suppliers include:
- Issuing VAT invoices,
- Filing VAT returns,
- Paying VAT,
- Maintaining records, and
- Applying VAT to cancellations and adjustments.
- Sector Impact: Food delivery and short-term accommodation platforms are commonly captured due to their operational control.
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