The Saudi General Authority of Zakat and Tax (GAZT) has issued Circular No. 2104001 on Force of Attraction rule in the context of permanent establishment. The circular provides information and guidance, including examples, on the Force of Attraction (FOA) rule and its application in Saudi Arabia according to the Income Tax Law and double tax avoidance agreements (DTAs) in the following contexts:
- FOA application under the Law in Saudi Arabia in the absence of a DTA between Saudi Arabia and t…