On Tuesday, 19/11/1442 AH, corresponding to 29/06/2021 AD, the First Appellate Division for Income Tax Interventions and Disputes, established by Saudi Arabia Royal Decree No. 65474/1439 on 23/12/1439 AH, convened at its headquarters in Riyadh. The Division met to consider the appeal submitted on 05/03/1439 AH, corresponding to 22/12/2020 AD, by the company (...) against the decision of the Second Tax Disputes Appeal Committee in Riyadh, numbered 25 for the year 1438 AH, regarding the objection numbered 38/10, related to the tax linkage for the years 1990 to 2012. This appeal was filed by the appellant against the General Authority of Zakat and Tax (GAZT). The initial decision in this matter is as follows:

First, in form:

Acceptance of the objection submitted by the taxpayer/company (...) in formal terms for the years from 1990 to 2012.

Second, in merits:

• 1- Rejection of the taxpayer's objection regarding the item of carried-forward losses differential based on the reasons provided in the decision.