According to recent reports, Saudi Arabia has issued internal guidance to its tax offices that for the purpose of withholding tax relief claims made under a tax treaty, a non-resident may be deemed to have a "virtual" service permanent establishment (PE) in the country. According to the guidance, a "virtual" PE may be deemed constituted if services are furnished under contract for a period exceeding the threshold set in the relevant tax treaty (generally 183 days within any 12-month period), …