Saudi VAT Refund on Real Estate Supplies: 30-Day Window | Hespah LLC [Skip to main content](#main-content)[![Hespah LLC](https://centralcdn.hespah.com/home_logolight_file2png.webp)](/en)Search More [Home](/en) [Learning Hub](/en/courses) [About us](https://hespah.com/who-we-are) [Blog](/en/blog) [Contact Us](/en/contact) Login[New Account](/en/register) 1. [Home](/en) / 2. [Blog](/en/blog) / 3. Reclaiming VAT on Real Estate Supplies: a 30-Day Window Reclaiming VAT on Real Estate Supplies: a 30-Day Window ======================================================= 2026-10-14 / 1 week ago On **13 October 2026** the Official Gazette (Umm al-Qura) published ZATCA Board of Directors Resolution No. (10-04-26), and it takes effect from the date of its publication. The resolution opens the door to recovering VAT that individuals paid on **real estate supplies** made before 17/2/1442H. The 30-day clock is already running. What changed for real estate supplies on 13 October 2026? --------------------------------------------------------- Publication in the Official Gazette brought into force the mechanisms implementing Royal Order No. (54152) dated 5/7/1447H. Their effect: VAT is **not due** on real estate supplies made by an individual who did not carry on a real estate activity on a continuous and regular basis for the purpose of generating income before 17/2/1442H — and that individual may reclaim what he paid. The resolution itself is dated 3/3/1448H, corresponding to 16/08/2026, and was issued at the Board's fourth meeting of 2026. Yet its second clause states that "this resolution shall apply from the date of its publication in the Official Gazette, and the date of publication shall constitute the date of approval of these mechanisms and procedures." So the date that matters to you is 13 October, not August: before publication there was no step you could take, and after it there is both a step and a deadline. The Board relied on Article (Five) of ZATCA's organisational statute approved by Council of Ministers Resolution No. (570) dated 22/9/1442H, and on Articles (Fifty) and (Fifty-Two) of the VAT Law issued by Royal Decree No. (M/113) dated 2/11/1438H and its amendments. ![Key data of ZATCA Resolution 10-04-26, its publication date and Royal Order 54152](https://centralcdn.hespah.com/uploads/emils/17919948840.jpeg "Key data of ZATCA Resolution 10-04-26, its publication date and Royal Order 54152") Who is the "individual" that owes no tax? ----------------------------------------- The resolution left nothing to interpretation; it defined its terms in the first clause. An **individual** is a natural person. **Real estate supplies** are those made by way of sale and transfer of ownership — not every real estate dealing. And **the tax** is the VAT computed as output tax on that supply. The relief is not unconditional. The Royal Order carved out one explicit case: where the individual made **more than one supply within twelve months whose aggregate value exceeds the mandatory registration threshold** under the GCC Unified VAT Agreement, approved by Royal Decree No. (M/51) on 3/5/1438H — a threshold of **SAR 375,000** — the tax is due on him and the non-liability does not apply. The test is practical, not theoretical: how many supplies fell inside a twelve-month window, and what they added up to. It is the same logic that governs [mandatory VAT registration](https://hespah.com/en/blog/vat-registration-saudi-arabia) in the first place. The question that decides your route: did you deduct input tax? --------------------------------------------------------------- This is the condition that forfeits the right to a refund, and many will overlook it. Clause (Second/1) grants the individual the right to file a refund claim **"unless he has deducted the input tax related to the real estate supplies that are the subject of the refund claim."** Clause (Second/5) confirms the same rule from the other side: where the individual did deduct input tax in the returns he filed with the Authority, Clause (First) of the Royal Order does not apply to him, and he may only benefit from the waiver of unpaid fines. Put plainly: whoever deducted the input tax has already taken the benefit, and does not take it twice. Review [your earlier VAT returns](https://hespah.com/en/blog/vat-return-filing-saudi-arabia) before doing anything else — this single question determines which row you are standing in. Real estate supplies: four situations, four routes -------------------------------------------------- Your route through the real estate supplies rules turns on two questions and no others: did you pay the tax, and did you deduct the input tax. Your situation The statutory route Reference You paid the tax and did not deduct input tax A refund claim before the Committees for Resolution of Zakat, Tax and Customs Violations and Disputes Second/1 You paid the tax and did deduct input tax No refund. The waiver of unpaid fines remains available to you Second/5 You did not pay, and the tax is not due The Authority cancels the tax and its fines by amending the return you filed or the assessment it issued Second/6 The tax genuinely is due and you carry unpaid fines Fines are cancelled after you settle the principal tax due Third Note how the third row differs from the first two: there you need no claim at all. The Authority amends the return or the assessment itself, because the money never left your pocket. ![Four situations and four routes for reclaiming VAT on real estate supplies](https://centralcdn.hespah.com/uploads/emils/17919948841.jpeg "Four situations and four routes for reclaiming VAT on real estate supplies") The 30-day deadline: where does the count start? ------------------------------------------------ Clause (Second/2) provides that "the period of (30) days for referring the claim directly before the adjudication circuits set out in the working rules of the Zakat, Tax and Customs Committees shall be counted... **from the date of its publication in the Official Gazette**." That publication date is 13 October 2026. The count is running now. Because how the first day is counted and how official holidays are treated are matters for the committees' own working rules, the right move is to file in the opening fortnight rather than at the edge of the deadline. For the wider context of these committees and their circuits, see our guide to [objecting to ZATCA decisions](https://hespah.com/en/blog/zatca-objection-appeal-process). What to do now -------------- 1. **Identify the real estate supplies in question.** A sale of real estate with transfer of ownership, occurring before 17/2/1442H. 2. **Apply the continuity and regularity test.** Did more than one supply within twelve months exceed SAR 375,000 in aggregate value? If so, the tax is due and your route is the fines waiver, not a refund. 3. **Check for input tax deduction.** Search your returns for any deduction of input tax tied to that supply. Its presence changes your route entirely. 4. **Assemble proof of payment.** A voluntary disclosure, a decision of the Authority, or a judicial decision of the committees — the resolution accepts all three. 5. **Confirm you have not recovered the amount elsewhere.** The claim is confined to the amount not previously recovered from any related government entity (Second/3). 6. **File the claim within the deadline** before the adjudication committees. 7. **Keep your documents after the refund.** The Authority may take statutory action to claim the tax and fines if it later establishes you were not entitled (Fourth). What the resolution does not cover ---------------------------------- Three limits should be clear. First: **tax evasion fines are excluded** from cancellation, expressly in Clause (Third) and in the Royal Order. Second: where the tax is genuinely due, the fines waiver is **conditional on settling the principal tax** first. Third: real estate supplies in this resolution are confined to sale and transfer of ownership, so do not extend the rule to other dealings by analogy. The Authority is expressly entitled to verify that the tax is not due under Clause (First), and that the individual has not already recovered the amount from another government entity. A claim gets examined; it is not accepted merely because it was filed. To understand the classification of the fines at issue, see [VAT penalties in Saudi Arabia](https://hespah.com/en/blog/vat-penalties-saudi-arabia). Frequently asked questions -------------------------- ### Does the resolution cover companies, or only individuals? Individuals. The resolution defines an "individual" as a natural person, and the whole rule on real estate supplies is built on that. Companies and establishments fall outside its scope. ### How does this relate to the Real Estate Transaction Tax? The cut-off date in the Royal Order is the entry into force of the Real Estate Transaction Tax provisions on 17/2/1442H (4 October 2020). Before it, real estate supplies sat within VAT; after it, they moved to RETT. The detail is in our article on [the Real Estate Transaction Tax, its scope and exemptions](https://hespah.com/en/blog/real-estate-transaction-tax-saudi). ### What if the tax genuinely was due from me? Then the refund is not yours, but the waiver of unpaid fines stands — for the period from the VAT Law coming into force on 14/4/1439H until 17/2/1442H, after settlement of the principal tax, and excluding evasion fines. ### Do I need a lawyer to file the refund claim? The resolution does not require one. But it refers expressly to the working rules of the Zakat, Tax and Customs Committees on referring the claim and its period, and those are procedural rules — so read them, or consult a specialist before filing, because the window is short. ### Where can I verify the official text? From Umm al-Qura directly. Both the resolution and the text of the mechanisms were published on 13 October 2026, and the links are in the sources below. Sources ------- - [Umm al-Qura — ZATCA Board of Directors Resolution No. (10-04-26) dated 3/3/1448H, published 13 October 2026](https://www.uqn.gov.sa/decisions-and-regulations/authorities/4002080) - [Umm al-Qura — Mechanisms and procedures for implementing Royal Order No. (54152) dated 5/7/1447H](https://www.uqn.gov.sa/decisions-and-regulations/rules-and-regulations/4002078) - [Zakat, Tax and Customs Authority](https://zatca.gov.sa/) *This article was published on 14 October 2026, based on what appeared in Umm al-Qura on 13 October 2026.* *This article is for informational purposes only and does not substitute for reviewing the official sources or consulting a specialist before taking any action.* Articles you might like ----------------------- [![Nitaqat Wage Floor Rises to SAR 5,000 Then SAR 6,000](https://centralcdn.hespah.com/265/conversions/cover-sm.webp)2026-10-26 ### Nitaqat Wage Floor Rises to SAR 5,000 Then SAR 6,000 The Nitaqat wage floor rises to SAR 5,000 after six months and SAR 6,000 after twelve, by royal directive of 25 October](/en/blog/nitaqat-wage-floor-2026)[![UAE e-Invoicing: the Provider Deadline Falls on 30 October](https://centralcdn.hespah.com/263/conversions/cover-sm.webp)2026-10-26 ### UAE e-Invoicing: the Provider Deadline Falls on 30 October E-invoicing in the UAE: appoint an accredited service provider by 30 October 2026 if revenues reach AED 50 million; go l](/en/blog/uae-einvoicing-asp-deadline)[![ZATCA Objection: The Full Appeal Path, Step by Step](https://centralcdn.hespah.com/138/conversions/cover-sm.webp)2026-10-06 ### ZATCA Objection: The Full Appeal Path, Step by Step A ZATCA objection runs on deadlines: 60 days to file a grievance, 90 for ZATCA to rule, 30 to settle or litigate. 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