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May 15, 2026

This Resolution constitutes the Executive Bylaws of the KSA Income Tax Law, providing detailed implementation rules. Based on the provided text, Article 4 of these Bylaws clarifies the concept of a dependent agent for non-residents. It defines an agent that creates a permanent establishment (PE) as one having authority to negotiate or conclude contracts on behalf of the non-resident, or one who maintains a stock of goods for regular order fulfilment. It further specifies that an insurance or reinsurance business conducted through an agent in the Kingdom is also deemed a PE, regardless of the agent's authority.

Article 4 - Agent

An agent referred to in Article 4 of the Income Tax Law means a dependent agent who has any of the following authorities:
1. To negotiate on behalf of a non-resident,
2. To conclude contracts on behalf of a non-resident,
3. To maintain a stock of goods, owned by a non-resident, in the Kingdom and to regularly fulfil customer orders on behalf of the non-resident.
A place from where a non-resident carries out insurance and/or reinsurance through an agent in the Kingdom, shall be deemed to be a permanent establishment of the non-resident, even though the agent is not authorized to negotiate and conclude contracts on behalf of the non- resident.