1Fourth Version | May 2026
Art. 33Status unknownSaudi ArabiaRegulation
Issued by Zakat, Tax and Customs Authority (ZATCA)
is limited to specific cases and is subject to certain exceptions stipulated in this regard(2).
This guideline provides guidance to taxable persons who supply services to non-GCC resident
customers, and as a transitional measure to all non-Kingdom residents. A diagram is added to
the appendix included in this document, with the aim of giving a clarification of how to apply the
relevant concepts to all cases.
2. Key Terms
“Customer”: is a defined term for VAT purposes, being: “A Person who receives Goods or
Services”(3). Additional context on the identification of the customer is provided in Chapter 4 of
this Guideline.
“GCC Territory”: Is a defined term for VAT purposes, being: “All territories of the GCC Member
States.”(4) For the purpose of this guideline, this must be read in conjunction with transitional
provisions requiring that Member States of the Gulf Cooperation Council have introduced VAT
and have an Electronic Services System in place with the KSA(5).
“Member State”: Unless the context dictates otherwise, references in this Guideline to a “Member
State” refer to a Gulf Cooperation Council State which has introduced VAT and has an Electronic
Services System in place with the KSA(6).
“Non-GCC Resident”: For the purposes of this guideline, this term refers to any Person that is
not Resident of any Member State. This means the person cannot have any fixed establishment
or Place of Residence in any Member State, even if the Person is also Resident in a non-GCC
country.
“Place of Residence”: Is a defined term for VAT purposes, being: “The location of Place of
Business or any other type of Fixed Establishment. In the case of a natural person, if he does
not have a Place of Business or Fixed Establishment, it will be his usual place of residence. If a
Person has a Place of Residence in more than one State, the place of residence will be considered
to be in the place most closely connected with the supply.(7)”
In practice, this means that a residence of a legal person can be created by:
Please note that these exceptions only apply to subjecting services provided to non-GCC residents to the zero rate.
(3) Article 1, Definitions, Unified VAT Agreement
(4) Article 1, Definitions, Unified VAT Agreement
(5) Article 79, Transitional provisions, Implementing Regulations
(6) Article 79, Transitional provisions, Implementing Regulations
The Arabic text is the legally binding version. The English translation is provided for guidance only.
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