Article 80 - Joint Liability

The application of the provisions of Article 29 of the Law is subject to all of the following:

1. Where an Entity located in the Kingdom joins a Multinational Enterprise Group that meets the Revenue Test, or otherwise becomes a part thereof pursuant to Article 38 of these Regulations, that Entity shall be held jointly and severally liable along with other Entities of the Multinational Enterprise Group in respect to Tax Due and administrative fines for the Fiscal Year during which it became the member.

2. Where a Constituent Entity which is located in the Kingdom changes its location to a jurisdiction other than the Kingdom, leaves a Multinational Enterprise Group that meets the Revenue Test, or otherwise ceases to become a member thereof pursuant to Article 38 of these Regulations, that Constituent Entity shall remain jointly and severally liable for any Tax Due and liabilities arising in respect of the Fiscal Years during which it was a member of the Multinational Enterprise Group including the entire Fiscal Year during which it ceased to become a member of the Multinational Enterprise Group or ceased to be located in the Kingdom.

The provisions of this Article shall also apply to a Joint Venture or a Joint Venture Subsidiary located in the Kingdom.