GTL Summary:

Document Type: IR - Implementing Regulations
Law: Value Added Tax Law
Decision Number: 3839-article-33
Year: 2016
Country: 🇸🇦 KSA
Official Name: Article 33 - Services Provided to Non-GCC Residents
Last updated at: 2025-11-27 14:38:44 UTC

Chapter 6 - Zero-Rated Supplies

Article 33 - Services Provided to Non-GCC Residents

  1. Except as stated in the second Paragraph of this Article, a Supply of services made by a Taxable Person to a Customer without a Place of Residence in any Member State shall be zero-rated.[42]

  2. The first Paragraph of this Article shall not be applicable in any of the following cases: [43]

    1. If the place of Supply of the services is in any Member State pursuant to the Special Cases listed in Articles 17 to 21 of the Agreement; This shall not include services supplied separately from the services whose place of supply falls in a Member State under those special cases, whether directly or indirectly related thereto. [44]

    2. If the Customer is a Resident of any Member State;

    3. If the Customer or any other Person related to the customer benefits directly from the services when such Customer or Person is situated in a Member State, and the other Person is not permitted to deduct the Input Tax on such services in full; or[45]

    4. If the services are performed in a tangible form in relation to tangible Goods which are located within a Member State during the Supply.[46]

  3. As an exception to subparagraphs c and d of paragraph 2 of this Article, services supplied by a provider of tax refund services to tourists shall be subject to the zero rate, in accordance with the provisions of Article 73 of these Regulations.[47]

Footnotes

[42] This Paragraph was amended pursuant to the Decision of the Board of Directors of the General Authority for Zakat and Income Tax No. (19-3-9), dated 30 October 1440H (corresponding to 3 July 2019). Prior to the amendment, the Paragraph read as follows:
'A Supply of services made by a Taxable Person to a Customer without a place of residence in any Member State is zero-rated, provided that each of the following conditions is met:

  1. The Supply of those services does not take place in any Member State under the Special Cases listed in Articles 17 to 21 of the Agreement

  2. The Taxable Person has no evidence that the Customer has any residence in any Member State and has evidence that the Customer is resident outside of Council Territory

  3. The benefit of the services is not received by the Customer or any other Person when that Person is situated in a Member State

  4. The services are not related to any tangible Goods or property located within a Member State during the Supply

  5. The Taxable Person intends that the services are consumed by the Customer outside of Council Territory

  6. The Taxable Person has no evidence that the benefit of the services will be enjoyed within Council Territory

[43] This Article was added pursuant to the Decision of the Board of Directors of the General Authority for Zakat and Income Tax No. (19-3-9), dated 30 October 1440H (corresponding to 3 July 2019)

[44] This clause was amended pursuant to Decision No. (22-09-05) dated 5 Jumada al-Awwal 1444 AH (corresponding to 29 November 2022). Prior to the amendment, the clause read as follows:
'a) If the place of Supply of the services is in any Member State pursuant to the Special Cases listed in Articles 17 to 21 of the Agreement;'

[45] This clause was amended pursuant to the decision of the Board of Directors of the Zakat, Tax, and Customs Authority No. (01-06-24) dated 17 Jumada al-Awwal 1446 AH, corresponding to 19 November 2024 AD. Prior to the amendment, the clause read as follows:
'(c) Where the customer or any other person benefits directly from the services while being physically present in any GCC Member State, and such other person is not entitled to recover input tax in full.'

[46] This clause was amended pursuant to the decision of the Board of Directors of the Zakat, Tax, and Customs Authority No. (01-06-24) dated 17 Jumada al-Awwal 1446 AH, corresponding to 19 November 2024 AD. Prior to the amendment, the clause read as follows:
'(d) Where the services are performed on tangible goods located in any GCC Member State during the time of supply.'

[47] This clause was added pursuant to the decision of the Board of Directors of the Zakat, Tax, and Customs Authority No. (01-06-24) dated 17 Jumada al-Awwal 1446 AH, corresponding to 19 November 2024 AD.

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