SZTAC 105/2020/IAR;2018/1520/Z
Expenses incurred by the company before its establishment and commencement of activities are considered, in principle, necessary expenses for achieving future production for the company after conducting its activities, necessitating the offsetting of those losses.
The fundamental basis for judicial decisions is their reliance on decisive rulings and decisions regarding the subject of the dispute.
Background
On Monday, 1442/03/16 AH, corresponding to 2020/11/02 AD, the First Appellate Chamber for Income Tax Violations and Disputes, established by Saudi Arabia Royal Decree No. 65474/1439 dated 1439/12/23 AH, based on Article 67(b) of the Income Tax Law issued by Saudi Arabia Royal Decree No. M1/1425 dated 1425/01/15 AH, and amended by Saudi Arabia Royal Decree No. M113/1438 dated 1438/11/02 AH, convened at its headquarters in Riyadh to consider the appeal submitted on 1438/11/21 AH by [Company Name] against the decision of the First Primary Zakat and Tax Objection Committee in Riyadh, numbered (28) for the year 1438 AH, issued in Case Number (37/27) brought by the appellant against the General Authority of Zakat and Income. The primary decision ruled as follows:
First, formally accepting the objection from [Company Name].
Second, regarding the subject matter: