Kingdom of Saudi Arabia

Value-Added Tax Public Consultation


01 What?

The Zakat, Tax and Customs Authority (ZATCA) has set in motion a public consultation on adding a new paragraph to Article 33 of the VAT Implementing Regulations on "Services Provided to Non-GCC Residents".

02 When?

12 October to 11 November 2022

03 How?

Concerned stakeholders may provide their inputs and comments on the KSA's Public Consultation Platform website

Proposed Addition:

Clause 3 of Article 33 of the VAT Implementing Regulations

KSA Supplier

Supply of services is zero-rated IF

Non-resident in the KSA

Facilitates the supply of taxable services (subject to15% VAT)

KSA Customer

The supply of services to a non-resident customer in any of the member states shall be zero-rated where it facilitates the supply of taxable services by that non-resident customer to a person in the KSA.

Note: No similar provision in other GCC States for Export of Services


  • VAT is not yet implemented.


  • Services are supplied to a non-resident customer and such customer was outside Bahrain at the time services were performed.
  • Services relate to tangible goods or real estate located outside Bahrain


  • VAT is not yet implemented.


  • Service or arranging of service is performed outside the State
  • Recipient is outside the UAE when the service is performed
  • Service is not directly related to real estate or movable personal asset in the UAE


  • Taxable supplier is resident in Oman
  • Customer is not residing in Oman
  • Customer is beneficiary of these services outside Oman
  • Place of supply of services is in Oman

Key Takeaways

  • KSA businesses currently charging 15% to non-resident recipients may qualify for 0% VAT under the addition.
  • Non-resident recipients incurring 15% VAT on services from KSA suppliers may be subject to 0% VAT, saving them from non-recoverable VAT if the recipients are based in a country without reciprocity agreement with the KSA.
  • Above-mentioned stakeholders must take active part in the polishing of this amendment by participating in the public consultation.

Contact Us

Markus Susilo
Markus Susilo
Partner- Payroll and Indirect Tax
Michel Ruitenberg
  Partner DIFC - Indirect Taxes