Eligibility checked before filing
We check the conditions before any step and tell you plainly if your case falls outside the royal order, without promising any particular outcome.
VAT refunds on real estate sales
Real Estate VAT Refund for Individuals — Refund Claims Under Royal Order 54152
Request an assessment
The form already has real estate selected; note the year of the sale, whether you paid the tax or penalties, and how many properties you sold in that period.
If you sold a property as an individual between 1 January 2018 and 4 October 2020 and paid VAT or related penalties on the sale, you may be entitled to claim it back under Royal Order 54152. Our licensed lawyers handle the whole file on your behalf: the eligibility review, the documents, filing the claim on the Hayad portal within the window, and following it until a decision is issued.
Matters we handle
- An individual who sold land, a house or a flat between 2018 and 2020 and paid VAT on the sale
- VAT paid after a voluntary disclosure or a ZATCA assessment
- VAT paid to comply with a decision of the Zakat, Tax and Customs Committees
- Late-payment or other penalties paid in connection with the property sale tax
- Unpaid real estate VAT or penalties, and a need to know how the royal order affects them
- Uncertainty about eligibility because more than one property was sold in the same period
The refund claim, from eligibility to decision
- 1Eligibility review: we check the sale date and your capacity in it, the number of property sales you made within 12 months, and whether you deducted input VAT on the property.
- 2Documents: we gather the transfer deed or sale contract, proof of the tax and penalties paid, and the relevant returns, assessments or decisions.
- 3Filing: we register the refund claim before the Zakat, Tax and Customs violations and disputes committees through the Hayad portal within the window.
- 4Follow-up: we follow the claim and answer what the circuit or ZATCA requests until a decision is issued; the decision rests with the competent body.
Why instruct Kawkaba Law for your refund claim?
A written fee agreement
We set the scope of work and the fees in writing before we begin, so you know in advance what the representation covers.
In person and remotely across the Kingdom
The claim is filed online through Hayad, so we can act for you wherever you are in Saudi Arabia, with our office in Jeddah for those who prefer to meet.
What Royal Order 54152 covers and who it applies to
Royal Order No. 54152 dated 5/7/1447H addresses the VAT charged on individuals' real estate sales before the Real Estate Transaction Tax took effect. The mechanisms to apply it were then issued by decision of the ZATCA board and published in Umm Al-Qura on Tuesday 13 October 2026.
The refund covers real estate supplies made by way of sale and transfer of ownership between 1 January 2018 and the start of the Real Estate Transaction Tax on 4 October 2020. An individual means a natural person, not a company or establishment.
Eligibility conditions under the published mechanisms:
- The seller is an individual (natural person) who paid VAT on the sale to ZATCA
- The seller was not carrying on a real estate business, meaning selling property regularly and continuously to earn income
- The seller did not make more than one real estate supply within 12 consecutive months whose total exceeded the mandatory VAT registration threshold
- The seller did not deduct input VAT related to the property in their returns
- The same amount has not already been refunded by another government body
The 30-day window: why this file cannot wait
The General Secretariat of the Zakat, Tax and Customs Committees announced that the refund claim is filed within 30 days of the date the mechanisms were published in the Official Gazette, that is, within 30 days of 13 October 2026. No prior objection to ZATCA is required before filing this claim.
The window is short compared with what the file needs: obtaining the transfer deed, gathering proof of payment and tracing returns or assessments going back to 2018. So we start the eligibility review as soon as we receive the basic details and prepare the claim while the documents are completed.
Why instruct a lawyer instead of filing the claim yourself?
The system lets an individual file the claim alone on Hayad, but whether it is accepted depends on details that are not always obvious at the start. Our lawyers handle the file from start to finish on your behalf, so you do not have to follow the procedure yourself:
- Conditions that defeat the refund, such as deducting input VAT or exceeding the registration threshold within 12 months, need a review of old returns before filing
- The 30-day window is short, and an incomplete or wrongly framed claim can use it up without result
- Proving payment of tax paid as far back as 2018 may mean tracing scattered returns, assessments and decisions
- Answering what the circuit or ZATCA requests while the claim is heard, within the set deadlines
- ZATCA may later reclaim a refund that proves unfounded, so the claim should rest on accurate documents from the start
What if the tax or penalties have not been paid yet?
If the tax is not due under the royal order and the individual has not paid it, ZATCA cancels the tax and related penalties by amending the return filed or the assessment issued, with no refund claim needed.
A person who deducted input VAT on the property does not qualify for the refund; their entitlement is limited to the cancellation of unpaid penalties under the set conditions. Penalties for tax evasion are not cancelled.
ZATCA may later reclaim anything cancelled or refunded if the entitlement proves unfounded, so the claim should rest on accurate documents from the start.
Documents needed for a real estate VAT refund claim
The documents depend on how and when the tax was paid; the file usually needs the following:
- The transfer deed or sale contract showing the date and value of the supply
- Proof of the VAT and penalties paid to ZATCA
- The tax return, voluntary disclosure or ZATCA assessment
- The committees' decision, if the payment was made to comply with one
- A list of any other property sales within 12 months of the sale date
- A bank account number (IBAN) in the claimant's name
Facing a legal matter or dispute? Let a specialist lawyer review it
Send your case details through the assessment form. A specialist lawyer contacts you during business hours with the next step, scope and written fees before any engagement.
- Ministry of Justice licence 441458
- Jeddah office · serving the Kingdom
- Strict professional confidentiality
Frequently asked questions
Who is entitled to a real estate VAT refund?
An individual (natural person) who sold a property between 1 January 2018 and 4 October 2020 and paid VAT or related penalties on the sale, provided they were not carrying on a real estate business, did not deduct input VAT on the property and have not been refunded the amount by another government body.
What is the deadline for filing the refund claim?
The claim is filed within 30 days of the publication of the mechanisms in Umm Al-Qura on 13 October 2026, through the Hayad digital litigation portal of the General Secretariat of the Zakat, Tax and Customs Committees.
Can I file the claim myself?
Yes, the system lets an individual file through the Hayad portal. Instructing a lawyer helps with reviewing the conditions that can defeat the claim before filing, assembling proof of payment, filing the claim correctly within the window, and following it and answering the circuit's requests until a decision is issued.
Does the refund cover the 5% Real Estate Transaction Tax?
No. The royal order deals with VAT paid on individuals' property sales before 4 October 2020; the Real Estate Transaction Tax applied after that date has its own rules and exemptions.
Are penalties refunded as well?
Yes. The refund claim covers tax penalties already paid in connection with the tax that was not due. Unpaid penalties are cancelled by ZATCA under the set conditions; penalties for tax evasion are not cancelled.
Do I need to object to ZATCA before filing?
No. According to the General Secretariat's guide, no initial objection to ZATCA is required before filing a claim for the refund of VAT on individuals' real estate supplies.
How much does a lawyer charge for a refund claim?
There is no fixed figure: fees follow the number of sales, the state of the documents and the stage of the claim. After the eligibility review we send a written fee proposal that you sign before we begin.
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