On 22/09/1442 AH, corresponding to 04/05/2021 AD, the First Appellate Division for Income Tax Violations and Disputes met at its headquarters in the city of Riyadh, in order to consider the appeal, submitted on 6/6/1438 AH, by a taxpayer, a company, on the decision of the Second Primary Zakat Objection Committee in Riyadh, no. 7 for the year 1438 AH, issued for the tax assessment lawsuit for the years from 2005 AD to 2009 AD. This had been filed by the appellant against the General Authority for Zakat and Income (ZATCA), in which the primary decision stipulated the following:

First: in terms of formality: the objection of the taxpayer, a company, to the tax assessment for the years 2005 AD to 2009 AD was accepted due to the reasons contained in the decision.

Second, objectively:

• 1. Rejecting the taxpayer’s objection to the clause not allowing the deduction of tax losses for the years 2004 to 2007 against the taxable income for the year 2009.