ZATCA Circular 2104001 details the application of the Force of Attraction (FOA) rule under KSA domestic law and relevant tax treaties. It explains that the FOA rule allows the Kingdom to tax income from sales or services conducted by a foreign head office if they are of the 'same or similar nature' as activities performed through a local Permanent Establishment (PE). The circular distinguishes between partial and global FOA, noting KSA's adoption of the partial model. It provides a definitive categorization of 14 treaties that include FOA provisions and 38 treaties that explicitly nullify its application.