Virtual Service PE impact in KSA
- The Oath
- Dr. Constantin Frank-Fahle, LL.M.
- Marcel Trost, LL.M.
The Kingdom of Saudi Arabia's (KSA) hybrid taxation system combines Income Tax and Zakat, with its Income Tax regime governed by Royal Decree No. M1/1425 (Related to the Income Tax Law) and Cabinet Decision No. 278/1424 (On the Approval of the Income Tax Law). For capital companies incorporated in KSA, income tax applies exclusively to shares owned, directly or indirectly, by non-GCC nationals. This aligns with KSA's classical taxation framework, which imposes income tax on non-residents engaging in activities within the Kingdom through a Permanent Establishment (PE).
Dr. Constantin Frank-Fahle and Marcel Trost, LL.M., LL.M. of emltc examine the Kingdom of Saudi Arabia's taxation system, focusing on the legal and tax implications of Virtual Service Permanent Establishments.

