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May 15, 2026

This Circular from the General Authority of Zakat and Tax (GAZT) standardises the procedure for implementing Double Taxation Avoidance Treaties (DTATs) concerning withholding tax (WHT). It clarifies that a resident payor must initially withhold tax at the statutory rate prescribed by KSA income tax law. To claim a refund for a non-resident payee eligible for a lower DTAT rate, the payor must submit a request to GAZT. This request must be supported by a refund letter from the payee and a certificate from the payee's tax administration confirming their tax residency status.

This is not an Official Translation:

CIRCULAR NO. (3227/19) DATED 06/09/1431H
(23/05/2010)

RE: AGREEMENTS FOR THE AVOIDANCE OF DOUBLE TAXATION & THE PREVEN- TION OF TAX EVASION WITH RESPECT TO TAXES ON INCOME TO WHICH THE KINGDOM IS A SIGNATORY ("DTAT")

AS OF 18 FEB 2021

With respect to circular No. 19/ 3227 dated 09/06/1431H (23/05/2010) on DTATs; DTATs determine the withholding tax rates on payments made by a resident of the Kingdom to a beneficiary who is a resident of the other contracting state ("Other State"). Such payments include dividends, royalties and income from debt claims (interest). In certain cases, the withholding tax rates under DTATs may be lower than the default rates stated in the income tax legislation. Upon a DTAT's entry into force, the General Authority of Zakat and Tax ("GAZT" or the "Authority") receives queries regard- ing the applicable tax rates under the DTAT, and eligibility to claim a refund from the Authority in the event tax is withheld at the higher statutory higher rate than that afforded under the DTAT.

In an effort to uniform the Authority's practices with respect to the implementation of DTATs, it is the Authority's position that where a payment is made from a resident of the Kingdom to a nonresident subject to withholding tax pursuant to the income tax legislation and the relevant, the following procedures shall be applied