In case the conditions of a treaty or an international agreement to which the Kingdom is party are inconsistent with the articles and provisions of this Law, the conditions of the treaty or international agreement shall prevail except for the provisions of Article 63 of this Law which are related to anti-tax avoidance procedures.
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This article establishes the legal hierarchy between the Kingdom's domestic tax law and its international commitments. It stipulates that where the conditions of a treaty or an international agreement to which the Kingdom is a party are inconsistent with the provisions of the Income Tax Law, the terms of the international agreement shall prevail. This ensures compliance with international obligations. However, a critical exception is specified: the provisions related to anti-tax avoidance procedures, as detailed in Article 63 of this Law, will take precedence and apply regardless of conflicting terms in an international agreement, thereby protecting the Kingdom's tax base.
Chapter 7 - Additional Rules for Determining the Tax Base
Article 35 - International Agreements
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