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If a resident establishment has rented equipment and ships from non-resident establishments, do non-resident establishments, in this case, fall under the permanent establishments regulations as stipulated in paragraph (b) of Article Four of the Tax Law? Or are the amounts paid to it subject to Withholding Tax?

If the non-resident establishment or anyone on its behalf carries out any kind of activity in relation to these equipment inside KSA such as operating, supervising, maintaining, or previewing the equipment, It is therefore deemed as a permanent establishment as stipulated in the provisions of paragraph (B) of Article 4 of the Tax Law, whereas if the non-resident establishment is not involved in the activities previously stated, rent will be subject to Withholding Tax as stipulated in the provisions of Article 68 of the Tax Law and Article 63 of the Implementing Regulations.​