ZATCA Circular 2303001 provides critical guidance on the creation of a Service Permanent Establishment (PE) under Article 5.3(b) of Double Taxation Agreements (DTAs). It clarifies that a PE is deemed to exist when a non-resident entity furnishes services through employees physically present in KSA for more than 183 days within a 12-month period. Once a PE is established, the entity is subject to KSA income tax on a net basis. The circular emphasizes the 'Within' test, requiring physical ground presence, and notes specific treaty exceptions where technical services may be classified as royalties subject to withholding tax.