Article 33 - Services Provided to Non-GCC Residents

Except as stated in the second Paragraph of this Article, a Supply of services made by a Taxable Person to a Customer without a Place of Residence in any Member State shall be zero-rated.

The first Paragraph of this Article shall not be applicable in any of the following cases:

1. If the place of Supply of the services is in any Member State pursuant to the Special Cases listed in Articles 17 to 21 of the Agreement; This shall not include services supplied separately from the services whose place of supply falls in a Member State under those special cases, whether directly or indirectly related thereto.

2. If the Customer is a Resident of any Member State;

3. If the Customer or any other Person related to the customer benefits directly from the services when such Customer or Person is situated in a Member State, and the other Person is not permitted to deduct the Input Tax on such services in full; or

4. If the services are performed in a tangible form in relation to tangible Goods which are located within a Member State during the Supply.

As an exception to subparagraphs c and d of paragraph 2 of this Article, services supplied by a provider of tax refund services to tourists shall be subject to the zero rate, in accordance with the provisions of Article 73 of these Regulations.