This ZATCA Tax Circular (Version 1, January 2025) explains how Withholding Tax (WHT) applies in the Kingdom of Saudi Arabia, both under the domestic Income Tax Law issued by Royal Decree No. (M/1) and its Regulations, and under the Double Taxation Agreements (DTAs) that KSA has concluded with more than 56 countries. It sets out who must withhold tax, the payments covered by Article 68 of the Law and Article 63 of the Bylaw, and the domestic WHT rates for management fees, royalties, dividends, rent, insurance, loan returns, technical and consulting services, freight and telecommunication services. It then explains, with worked examples, how DTA provisions allocate taxing rights for business profits, income from immovable property, international shipping and air transport, dividends, income from debt-claims, royalties, fees for technical services, independent personal services and directors' fees. Finally, it describes the two procedures for claiming DTA relief on WHT before ZATCA, the benefit at source procedure and the refund procedure, including the required documentation such as a Tax Residency Certificate, embassy or Apostille authentication, and the five-year statute of limitation.
Implementation of Withholding Tax (WHT) Under the Double Taxation Agreement
Version 1 | January 2025
Contents
1. Introduction
2. Situational Context
3. Withholding tax scope in KSA under the domestic tax law and Double Taxation Agreement
3.1. Application of WHT under KSA Domestic tax Law
3.2. Application of WHT under KSA DTAs
Continue Reading
Access Full Content
You're viewing a preview of this document. Please log in to unlock the complete content, annotations, and research tools.
Click here to view details of the free plan and the subscriptions we offer.