Executive summary
The Saudi Arabian General Authority for Zakat and Tax (GAZT), in April 2021, published Circular No. 2104001, entitled Force of Attraction rule in the context of permanent establishment. The Circular confirms the GAZT’s approach to applying the force of attraction principle under the Income Tax Law and several of Saudi Arabia’s tax treaties. The GAZT has affirmed that when a treaty does not contain a force of attraction rule, only the profits that are directly attributable to a p…