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HMRC internal manual

Double Taxation Relief Manual

Saudi Arabia: Source state taxation


There are two rates of source state taxation provided by Article 10.

Qualifying dividends paid by a property investment vehicle can be taxed at a rate of 15%.

In all other cases the rate will be 5%.

Income from debt-claims

Any income from debt-claims is taxable only in the state in which the beneficial owner is resident (Article 11).


Under Article 12, the term “royalties” includes the leasing of industrial, commercial or scientific equipment. Such rentals can be taxed by the state in which the equipment is used at a rate of 5%.

Any other royalty can be taxed by the source state at a rate of 8%.