GTL Summary:

This Resolution constitutes the Executive Bylaws of the KSA Income Tax Law, providing detailed implementation rules. Based on the provided text, Article 4 of these Bylaws clarifies the concept of a dependent agent for non-residents. It defines an agent that creates a permanent establishment (PE) as one having authority to negotiate or conclude contracts on behalf of the non-resident, or one who maintains a stock of goods for regular order fulfilment. It further specifies that an insurance or reinsurance business conducted through an agent in the Kingdom is also deemed a PE, regardless of the agent's authority.

Document Type: ERS - Executive Regulations
Law: Income Tax Law (Royal Decree No M/1 - 21 Feb 2004)
Decision Number: executive-regulations-1535-article-4
Year: 2019
Country: 🇸🇦 KSA
Official Name: Article 4 - Agent
Last updated at: 2026-01-05 08:39:39 UTC

Article 4 - Agent

  1. An agent referred to in Article 4 of the Income Tax Law means a dependent agent who has any of the following authorities:

    1. To negotiate on behalf of a non-resident,

    2. To conclude contracts on behalf of a non-resident,

    3. To maintain a stock of goods, owned by a non-resident, in the Kingdom and to regularly fulfil customer orders on behalf of the non-resident.

  2. A place from where a non-resident carries out insurance and/or reinsurance through an agent in the Kingdom, shall be deemed to be a permanent establishment of the non-resident, even though the agent is not authorized to negotiate and conclude contracts on behalf of the non- resident.

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