This Tax Bulletin clarifies the tax treatment of technical and consulting services provided by non-residents to Kingdom residents under the Income Tax Law and Double Taxation Avoidance Agreements. It defines these services per Article 63 of the Implementing Regulations, distinguishing them from know-how transfers and supply contracts. The guide details the application of the 5 per cent withholding tax mandated by Article 68 of the Law. Furthermore, it examines the interaction with tax treaties, specifically regarding permanent establishments, business profits, and technical service fees, explaining when treaty rates or exemptions supersede domestic statutory provisions for cross-border transactions.
Tax Bulletin: Tax Treatment of Technical or Consulting Services in accordance with the Income Tax Law and Double Taxation Avoidance Agreements
First Edition, 1 December 2025 G
Contents
1. Introduction
2. What is meant by Technical and Consulting Services
2.1 Know-how - Transfer of Knowledge - and Technical and Consulting Services
2.2 Supply Contracts Accompanied by Technical and Consulting Service
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