Skip to main content
Industries

The rules and risks of your industry, across borders.

Licences, value chains and the questions businesses in each industry ask first, with the services that usually apply.

Ask about your industry

Licences, approvals and first steps.

Ask WONE Global what applies to your industry in a market, with the sources shown.

Ask WONE Global→
People & firms

The WONE Global Partners in each market.

Named senior professionals, each admitted as the one firm for a service in their country, and the firms they lead.

For professional firms

Lead your service in your market.

One Partner per service, per country, admitted by review against published criteria.

Open Partnerships→
Insights

Sourced answers on doing business across borders.

Every statement is dated and sourced, and says whether it has been checked or professionally reviewed.

Ask WONE Global

Ask your question.

Answers come from statements checked against official sources, with the sources shown. Research, not advice.

Ask WONE Global→

Germany ↔ GCC · Worked example

A German engineering firm sets up a Saudi project company to deliver a contract

A German engineering company forms a project company in Saudi Arabia, alone or with a Saudi partner, to deliver an engineering contract, typically for a government or state-linked client. It must register its investment with the Saudi Ministry of Investment, meet ownership, procurement and local content rules, and manage Saudi and German tax on the project without a comprehensive Germany–Saudi tax treaty.

Source-checked research100% of statements checked against a source31 checked against an official source9 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed

This journey assumes

  • The German company is a GmbH or AG resident in Germany, not part of a financial services group.
  • The Saudi contract covers engineering, supply and site work; it does not involve defence or other excluded or specially licensed activities.
  • The German company will hold at least 10% of the Saudi project company from the outset.
  • Some German engineers will be seconded to Saudi Arabia for a fixed period, while other staff are hired locally.
  • Rules are stated as at 19 October 2026; the regional headquarters rule and treaty position must be reconfirmed before signing.

If any assumption is wrong for your business, the conclusions change. Ask WONE Global to re-run the analysis with your facts.

Both sides of the border, issue by issue

Each row is one part of the work. The left and right columns show what each country's rules require, so you can see where one side's decision constrains the other.

Part of the workGermanySaudi Arabia

Funding the project company and registering the investment

Germany places no approval requirement on investing abroad, but cross-border payments must be reported to the Bundesbank. In Saudi Arabia every foreign investor must register with the Ministry of Investment before investing, and a contractor holding a government contract can use a temporary registration that lasts only as long as the contract.

Germany
  • Capital injections, shareholder loans and fees paid to or received from Saudi Arabia must be reported to the Deutsche Bundesbank by the German company. Payments of up to EUR 50,000, payments for exports or imports of goods and loans of up to twelve months are exempt.12
  • Corporate documents that Saudi authorities ask for, such as the commercial register extract and accounts, can in principle carry a German apostille, because the Apostille Convention has been in force for Saudi Arabia since 7 December 2022. Check with the Ministry of Investment and the notary which form it accepts, because its investor guide still refers to embassy certification.34
More in the Germany guide →
Saudi Arabia
  • A foreign investor must register with the Ministry of Investment (MISA) before making any investment. For a regular registration a foreign company files its commercial registration and its latest financial statements, which the investor guide says must be certified by the Saudi embassy.54
  • A foreign company that has already won a government contract can apply for a temporary investment registration, supported by a letter from the government authority or the contract itself. It covers the contract period and ends with the contract, which suits a single project but not a lasting Saudi business.6
More in the Saudi Arabia guide →

Choosing the Saudi vehicle for the contract

The choice is usually between a wholly owned limited liability company, a joint venture with a Saudi partner, or contracting through a branch or temporary registration. Ownership rules for engineering activities, the regional headquarters rule for government contracts and the German tax treatment of each route all point in different directions, so they need to be weighed together.

Germany
  • If the project company is a Saudi subsidiary, its profits reach Germany as dividends, of which 95% is effectively exempt from German corporate income tax where the German parent held at least 10% at the start of the calendar year.7
  • If the work is done through a Saudi branch or permanent establishment of the German company, the Saudi profits form part of the German company's taxable income and Saudi income tax is credited under § 26 KStG, up to the German tax on that income, because no comprehensive treaty exempts them.89
More in the Germany guide →
Saudi Arabia
  • A limited liability company can be formed by one or more individuals or legal entities, with each partner's liability limited to its contribution, which makes it the usual vehicle for a project company.10
  • A wholly foreign-owned engineering consultancy must show a presence in at least four countries and at least ten years of experience. A professional activity registered with a Saudi partner needs 25% Saudi participation, with both partners licensed in the same field.1112
  • In a joint venture, income tax at 20% applies to the share of profits attributable to non-Saudi owners and zakat at 2.5% to the share attributable to Saudi and GCC owners, so the partner mix changes the tax profile.13
  • Since 2024 Saudi government agencies have been barred from contracting with foreign companies that have no regional headquarters in the Kingdom, subject to exceptions such as contracts below SAR 1 million. Reports in 2026 suggest this rule has been relaxed; confirm the current position before relying on any vehicle.14
More in the Saudi Arabia guide →

Tax without a comprehensive Germany–Saudi treaty

Germany and Saudi Arabia have only an air transport tax agreement, so there is no treaty to cap Saudi withholding taxes, set a construction permanent establishment threshold or allocate taxing rights on project profits. Saudi domestic rates apply in full and Germany relieves double taxation only through its own exemption and credit rules.

Germany
  • The only Germany–Saudi double tax agreement, signed on 8 November 2007, covers air transport enterprises and their employees. Engineering profits, dividends and fees fall under each country's domestic law.159
  • The German parent pays corporate income tax at 15% for assessment periods up to 2027, plus trade tax set by its municipality. Saudi tax on branch profits can be credited; dividends from a Saudi subsidiary are 95% exempt from corporate income tax.161787
More in the Germany guide →
Saudi Arabia
  • The project company pays income tax at 20% on the share of profits attributable to non-Saudi owners; a non-resident with a Saudi permanent establishment is taxed on its attributable profits in the same way.18
  • Payments from the Saudi company to the German parent bear Saudi withholding tax: 5% on dividends and loan charges, 5% on technical and consulting services, 15% on royalties, 20% on management fees and 15% on other payments. With no comprehensive treaty, the ZATCA treaty relief procedure is not available to reduce them.19202122
  • Where the German company supplies equipment from Germany and the project company or a branch does the site work, Saudi regulations treat only the ancillary onshore work (installation, assembly, maintenance, training) as Saudi-source income, so the contract split matters.23
  • VAT at 15% applies to taxable supplies in Saudi Arabia, including construction and engineering services delivered there.24
More in the Saudi Arabia guide →

The government contract, local content and compliance

Most large Saudi projects are let by government entities under the Government Tenders and Procurement Law, with price preferences for local content and disputes against the state heard by the Board of Grievances. On the German side, export controls on project equipment and German bribery law follow the company abroad.

Germany
  • Equipment shipped from Germany for the project needs an export authorisation if it is listed in Part I of the German Export List, and EU dual-use controls apply in addition.25
  • German bribery offences extend to bribery of foreign public officials, so payments and benefits connected with winning or running a Saudi government contract are within German criminal law.26
Saudi Arabia
  • Procurement by government entities is governed by the Government Tenders and Procurement Law and runs through the Etimad electronic portal.27
  • National products receive a price preference: a competing foreign product is evaluated as if its price were 10% higher, and high-value contracts can weight local content commitments in the financial evaluation.28
  • Under the Saudi Civil Transactions Law, agreed compensation such as delay damages is not payable if the contractor proves no harm, and the court may reduce or increase it, so liquidated damages clauses do not work exactly as under German law.29
  • Disputes between private contractors and the government generally go to the Board of Grievances rather than the commercial courts.30

Engineers sent from Germany and staff hired in Saudi Arabia

German engineers seconded for a fixed period can stay in German social insurance under the Ausstrahlung rule, but they still need Saudi work permits. Saudi hires bring Saudisation targets and different social insurance costs for Saudi and non-Saudi staff.

Germany
  • Employees sent to Saudi Arabia from a German employment relationship for a period limited in advance remain in German compulsory social insurance. This research did not confirm whether Germany and Saudi Arabia have a social security agreement, so the domestic rule is the starting point.31
  • German contributions therefore continue on seconded salaries, for example pension insurance at 18.6% and unemployment insurance at 2.6% in 2026, shared between employer and employee up to the contribution ceiling.32
More in the Germany guide →
Saudi Arabia
  • A non-Saudi may not work in Saudi Arabia without a work permit, which requires lawful entry, skills the country needs and a contract with an employer.33
  • For non-Saudi employees the employer pays social insurance of 2% for occupational hazards only; for Saudi employees contributions total 21.5% of salary. There is no personal income tax on employment income.3435
  • Nitaqat places employers in bands by Saudisation rate, and a low band restricts new work visas, so local hiring plans affect how many expatriate engineers can be brought in.36
More in the Saudi Arabia guide →

Moving money back and resolving disputes

Saudi law allows investors to transfer profits and capital freely, subject to withholding tax. Both countries apply the New York Convention, and a bilateral investment treaty has been in force since 1999, which matters for a contractor exposed to a state counterparty.

Germany
  • Germany has applied the New York Convention since 1961 without reservations, so an arbitral award made in Saudi Arabia can be enforced in Germany under it.37
  • The Germany–Saudi Arabia bilateral investment treaty has been in force since 8 January 1999; check whether the project company and its contracts count as protected investments.38
Saudi Arabia
  • Investors may transfer funds into and out of Saudi Arabia without delay, including profits and sale proceeds, in any recognised currency; withholding tax still applies to outbound payments.39
  • Saudi Arabia applies the New York Convention only to awards made in another contracting state, which includes Germany, so a seat in Germany or another contracting state keeps the award within the Convention.40

Structures to consider

01

Wholly owned Saudi limited liability company as the project company54101118192114

Fits when The German firm meets the conditions for full foreign ownership of its engineering activity, expects further Saudi work after this contract and wants liability ring-fenced from the German parent.

Watch for MISA registration with certified parent documents; four-country and ten-year conditions for a wholly foreign-owned engineering consultancy; 20% income tax and Saudi withholding on payments to Germany with no treaty relief; check the current regional headquarters rule for government contracts.

02

Joint venture company with a Saudi partner121328

Fits when The firm does not meet the full foreign-ownership conditions, needs a local partner for classification or local content, or the client expects Saudi participation.

Watch for Professional activities need 25% Saudi participation with both partners licensed in the same field; zakat on the Saudi share and income tax on the foreign share; shareholder agreement and exit terms must work under Saudi law.

03

Temporary registration or branch for a single government contract61889

Fits when The firm has already won one government contract and does not plan a lasting Saudi presence.

Watch for The temporary registration ends with the contract; the German company is directly exposed to Saudi tax as a permanent establishment and to contract liabilities; German tax relief is by credit only.

These are the structures businesses commonly weigh, not a recommendation. The right one depends on the facts listed under "What we need from you".

What has to happen first

  1. Both sidesMap the contract: client (government or private), scope split between offshore supply and onshore works, duration and local content requirements.
  2. Both sidesConfirm with advisers the current Saudi rule on contracting with foreign companies without a regional headquarters, and the German and Saudi tax position in the absence of a comprehensive treaty.After step 1
  3. Saudi ArabiaChoose the vehicle (wholly owned LLC, joint venture, branch or temporary registration) and check the engineering ownership conditions.After step 2
  4. GermanyBoard of the German parent approves the investment, funding and any parent guarantees; obtain commercial register extracts and accounts with apostille or embassy certification as MISA requires.After step 3
  5. Saudi ArabiaRegister the investment with MISA (regular or temporary registration) and incorporate the company through the Saudi Business Center.After step 4
  6. Both sidesOpen the Saudi bank account, inject capital and report the payment to the Bundesbank where it exceeds the exemption threshold.After step 5
  7. Saudi ArabiaRegister with ZATCA for income tax, withholding tax and VAT, and set up compliant e-invoicing.After step 5
  8. Both sidesPut intercompany agreements in place for equipment supply, engineering services, staff secondment and guarantees, priced at arm's length, and budget Saudi withholding tax on each payment type.After step 3, 5
  9. GermanyCheck export licensing for equipment and technology shipped from Germany.After step 1
  10. Both sidesPlan secondments: German social insurance under the Ausstrahlung rule, Saudi work permits, and Saudisation for local hires.After step 5
  11. Saudi ArabiaBid or sign through Etimad, with local content commitments, delay damages and dispute resolution clauses reviewed under Saudi law.After step 5, 8
  12. Both sidesOngoing: Saudi tax returns within 120 days of year end, monthly withholding filings, German tax returns crediting Saudi tax, and repatriation of profits subject to 5% dividend withholding.After step 11

What we need from you before anyone can advise

  • Who the client is (a government agency, a state-owned company or a private developer) and whether the contract is already awarded.
  • How the contract splits between equipment supplied from Germany and work performed in Saudi Arabia, and how long site work will last.
  • Whether the German firm meets the full foreign-ownership conditions (presence in four countries, ten years of experience) for its activity.
  • Whether a Saudi partner is wanted or required, and on what terms.
  • How many German engineers will be seconded, for how long, and whether local hiring can meet Saudisation targets.
  • Group consolidated revenue (for Pillar Two) and the German parent's municipality (for trade tax).
  • Whether the group already has, or plans, a regional headquarters in Saudi Arabia.

What this guide does not yet confirm

These points need checking with a qualified local professional before you rely on them.

  • The Federal Ministry of Finance list of German tax treaties as at 1 January 2026 could not yet be checked; the absence of a comprehensive Germany–Saudi treaty relies on a January 2025 GTAI publication and the 2007 air transport agreement.
  • The current status of the Saudi rule barring government agencies from contracting with foreign companies without a regional headquarters could not be confirmed; 2026 news reports of a relaxation or exemption framework could not yet be checked.
  • The Saudi Income Tax Law definition of a permanent establishment for construction, installation and supervisory projects, and any time threshold, was not confirmed.
  • Whether Germany and Saudi Arabia have a social security agreement was not confirmed; the German overview page could not yet be checked.
  • Contractor classification requirements for Saudi government works contracts were not researched.
  • German trade tax treatment of dividends from a foreign subsidiary (Trade Tax Act) and German controlled foreign company rules were not reviewed for this journey.
  • Whether MISA now accepts apostilled German documents in place of embassy certification was not confirmed.
  • German export credit guarantees and Saudi bank guarantee practice for performance bonds were not researched.

Brief for your advisers

Questions to put to your advisers in each country. Copy them, or download them as a text file to send with your requirement.

  1. Saudi counsel: does the client agency still require a regional headquarters to contract with us, and which exemption applies to this contract?
  2. Saudi counsel: do we qualify for a wholly owned engineering company, or do we need a Saudi partner, and is a temporary registration enough for this contract?
  3. Saudi tax adviser: when does our site work create a permanent establishment under Saudi domestic law, and how should the supply and works elements be split?
  4. Saudi tax adviser: which withholding rate applies to each payment we will receive (engineering services, management fees, licences, interest), and how will ZATCA classify them?
  5. German tax adviser: how are Saudi branch profits or subsidiary dividends taxed in Germany, including trade tax, and how much Saudi tax can we credit without a treaty?
  6. German social insurance adviser: does the Ausstrahlung rule cover our secondees for the full project, and is there any Germany–Saudi social security arrangement?
  7. Export control adviser: does any equipment, software or technical data we send need a German or EU licence?
  8. Contract counsel: how will delay damages, limitation of liability and arbitration clauses be applied against a Saudi government client?

Who can help, on each side

Germany

Saudi Arabia

Sources and review status

Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.

  1. Residents must report incoming and outgoing cross-border payments to the Deutsche Bundesbank. Residents (Inländer) under the Foreign Trade and Payments Ordinance; reporting deadlines in § 71 Abs. 6 AWV; exemptions in de-banking-002.

    Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) — § 67 AWV – Meldung von Zahlungen · § 67 Abs. 1 AWV · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  2. Payments of up to EUR 50,000 (or the equivalent in another currency), payments for the import or export of goods and short-term loans of up to twelve months are exempt from the Bundesbank payment reporting duty. Exemptions from § 67 Abs. 1 AWV.

    Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) — § 67 AWV – Meldung von Zahlungen · § 67 Abs. 2 AWV · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  3. The Hague Apostille Convention is in force for India (from 14 July 2005), Saudi Arabia (7 December 2022), Singapore (16 September 2021), the United Kingdom (24 January 1965), the United States (15 October 1981), Germany (13 February 1966) and France (24 January 1965). Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents. Some contracting states have objected to particular accessions (India is marked with an objection), in which case the Convention does not apply between those states; check the pair concerned.

    Hague Conference on Private International Law (HCCH) — Status table: Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents · Entries for each state · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The status table listed 130 contracting parties when checked.

  4. For regular investment registration, a foreign company must provide a copy of its commercial registration certified by the Saudi Embassy and its financial statements for the last fiscal year authenticated by the Saudi Embassy, plus any activity-specific requirements. Regular registration of foreign legal persons; holders of a Special Residency Permit are exempt from these document requirements.

    Ministry of Investment (MISA) — Investor Guide, 13th Edition 03-2026 · Regular registration requirements; Section 05.00 activity requirements · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  5. A foreign investor must register with the Ministry of Investment before engaging in any investment in Saudi Arabia. Applies to foreign investors generally; investments in securities governed by the Capital Market Law are outside this requirement.

    Ministry of Investment (MISA) — Investment Law (official English translation, Bureau of Experts at the Council of Ministers) · Article 7(2) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  6. MISA's temporary investment registration is for foreign companies that have obtained a government contract, requires a letter from the government authority or the project contract covering the contract period, and ends at the end of the contract. The fee for the full registration period must be paid within 30 days of notification or the registration is void; annual updates also apply.

    Ministry of Investment (MISA) — Investor Guide · Section 5.1.2, Category 3 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  7. Dividends received by a German corporation from another company are left out of its taxable income, but 5% of them is treated as a non-deductible expense, so in effect 95% is exempt from corporate income tax. Applies only where the German company held at least 10% of the capital directly at the start of the calendar year (§ 8b(4) KStG); smaller holdings are taxed in full. Trade tax on foreign dividends follows separate rules in the Trade Tax Act that were not reviewed here.

    Federal Ministry of Justice (gesetze-im-internet.de) — Körperschaftsteuergesetz (KStG) § 8b Beteiligung an anderer Körperschaften und Personenvereinigungen · § 8b Abs. 1 Satz 1, Abs. 4 Satz 1, Abs. 5 Satz 1 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  8. A German corporation with foreign income can credit foreign tax that corresponds to German corporate income tax against its German corporate tax, applying the foreign tax credit rules of § 34c EStG. Unlimited taxpayers (German-resident corporations), for example on the profits of a Saudi branch or permanent establishment; the credit is limited to the German corporate tax attributable to the foreign income (§ 26(2) KStG).

    Federal Ministry of Justice (gesetze-im-internet.de) — Körperschaftsteuergesetz (KStG) § 26 Steuerermäßigung bei ausländischen Einkünften · § 26 Abs. 1 Satz 1 Nr. 1 and Abs. 2 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  9. Germany Trade & Invest states that a double taxation agreement between Germany and Saudi Arabia exists only for taxes on the income and capital of air transport enterprises, so there is no comprehensive income tax treaty between the two countries. Ordinary business income, dividends, interest, royalties and service fees fall outside any treaty, so each country applies its domestic rules and Germany gives unilateral relief.

    Germany Trade & Invest (GTAI) — Steuerrecht in Saudi-Arabien (10 January 2025) · Section on Doppelbesteuerungsabkommen · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    GTAI is the German federal economic development agency. The Federal Ministry of Finance list of treaties as at 1 January 2026 could not yet be checked, so the absence of a comprehensive treaty at October 2026 relies on this January 2025 publication and the treaty law on gesetze-im-internet.de.

  10. A limited liability company may be founded by one or more individuals or legal entities, and each partner's liability is limited to its capital contribution. Limited liability companies under the Companies Law; the Ministry of Commerce service page states no minimum capital.

    Ministry of Commerce — Establish a limited liability company (e-service details) · Service overview · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  11. A 100% foreign-owned engineering consultancy must have a presence in at least four countries and at least 10 years of experience. Engineering consulting activity registered with the Ministry of Investment.

    Ministry of Investment (MISA) — Investor Guide, 13th Edition 03-2026 · Section 05.00, activity requirements table (engineering consulting) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  12. Professional activities registered with a Saudi partner require 25% Saudi participation, both partners must be licensed in the same field, and any non-professional partner's share may not exceed 30%. Professional activities (for example engineering and similar licensed professions) registered with the Ministry of Investment.

    Ministry of Investment (MISA) — Investor Guide, 13th Edition 03-2026 · Section 05.00, activity requirements table (professional activities) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  13. In Saudi Arabia, income tax of 20% applies to the share of net adjusted profits attributable to non-Saudi owners, while zakat at 2.5% applies to the zakat base attributable to Saudi and GCC owners. Mixed-ownership companies pay both on the respective shares.

    PwC Worldwide Tax Summaries — Saudi Arabia: Corporate - Taxes on corporate income · Income tax; Zakat (last reviewed 29 July 2026) · Checked 18 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source; ZATCA pages not yet checked for this point.

  14. Under regulations approved by the Council of Ministers on 27 December 2022, Saudi government agencies may not contract with foreign companies that have no regional headquarters in Saudi Arabia, or with their related parties, from 1 January 2024. Applies to all government agencies, not only those under the Government Tenders and Procurement Law. Does not apply to works or procurements estimated below SAR 1 million or executed outside the Kingdom. Exceptions include a single technically acceptable offer, a best technical offer priced at least 25% below the next, emergencies, and work only non-RHQ companies can perform; the agency must report its reasons to the General Auditing Bureau and the Expenditure and Project Efficiency Authority within 30 business days of signing.

    Clyde & Co — Saudi Arabia Regional Headquarters Programme: Contracting with government entities · Article, January 2023 · In force from 1 January 2024 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source (law-firm briefing, January 2023). No official Saudi page stating the contracting rule was found. News reports in 2026 indicate that the rule has since been relaxed or given a formal exemption framework; those reports could not yet be checked, so the current rule must be confirmed with the contracting agency or the Ministry of Investment.

  15. Germany and Saudi Arabia signed an agreement in Berlin on 8 November 2007 to avoid double taxation of the income and capital of air transport enterprises and the remuneration of their employees, approved in Germany by a law of 4 August 2008. Air transport enterprises and their employees only; it is not a comprehensive income tax treaty. Published in BGBl. 2008 II p. 782.

    Federal Ministry of Justice (gesetze-im-internet.de) — Gesetz zu dem Abkommen vom 8. November 2007 zwischen der Bundesrepublik Deutschland und dem Königreich Saudi-Arabien zur Vermeidung der Doppelbesteuerung auf dem Gebiet der Steuern vom Einkommen und vom Vermögen von Luftfahrtunternehmen und auf dem Gebiet der Steuern von den Vergütungen ihrer Arbeitnehmer (DBAG SAU) · Title and Article 1 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  16. Corporate income tax is 15 percent of taxable income for assessment periods up to and including 2027. Corporations subject to Körperschaftsteuer; solidarity surcharge and trade tax are charged in addition.

    Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) — § 23 KStG – Steuersatz · § 23 Abs. 1 KStG · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  17. Trade tax is assessed by applying a base rate (Steuermesszahl) of 3.5 percent to trade income; an allowance of EUR 24,500 applies only to individuals and partnerships. Gewerbesteuer; corporations receive no allowance under § 11 Abs. 1 Nr. 1.

    Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) — § 11 GewStG – Steuermesszahl und Steuermessbetrag · § 11 Abs. 1 Nr. 1 and Abs. 2 GewStG · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  18. Income tax is charged at the standard rate of 20% on taxable income that does not qualify for a special regime. Non-Saudi shareholdings in resident capital companies and non-residents with a permanent establishment; oil and hydrocarbon production is taxed under separate rates.

    Zakat, Tax and Customs Authority (ZATCA) — Guideline for Regional Headquarters in KSA, Second Version, May 2026 · Non-qualifying activities (standard income tax rate) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Stated by ZATCA in the RHQ guideline as the standard rate for non-qualifying income. PwC Worldwide Tax Summaries also states a 20% rate on net adjusted profits.

  19. Withholding tax of 5% applies to dividends and to loan charges paid to non-residents. Kingdom-source payments to non-residents; treaty rates may reduce the rate.

    Zakat, Tax and Customs Authority (ZATCA) — General Guideline for Withholding Tax in accordance with the provisions of the Income Tax Law and its Implementing Regulations, Second Version, May 2026 · Withholding tax rates table · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  20. Withholding tax of 15% applies to royalties and 20% to management fees paid to non-residents. Kingdom-source payments to non-residents; treaty rates may reduce royalty rates.

    Zakat, Tax and Customs Authority (ZATCA) — General Guideline for Withholding Tax in accordance with the provisions of the Income Tax Law and its Implementing Regulations, Second Version, May 2026 · Withholding tax rates table · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  21. Withholding tax of 5% applies to technical and consulting services, rent and international telecommunications, while other payments to non-residents not specifically listed are taxed at 15%. Kingdom-source payments to non-residents.

    Zakat, Tax and Customs Authority (ZATCA) — General Guideline for Withholding Tax in accordance with the provisions of the Income Tax Law and its Implementing Regulations, Second Version, May 2026 · Withholding tax rates table · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  22. To apply treaty withholding rates at source, the payer applies to ZATCA through its e-services portal with the non-resident's tax residency certificate, ZATCA's treaty form authenticated by the Saudi embassy or apostilled, and an undertaking to settle any resulting tax; otherwise the domestic rate is withheld and a refund claimed. Payments to residents of countries with a double taxation agreement with Saudi Arabia; treaty claims are subject to a five-year limitation period.

    Zakat, Tax and Customs Authority (ZATCA) — Tax Circular: WHT Implementation Under Double Taxation Agreement, Version 1, January 2025 · Applying treaty rates: benefit at source and refund methods · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  23. Under the Saudi income tax implementing regulations, a contract to supply goods into the Kingdom does not give rise to Saudi-source income unless it includes ancillary work performed in the Kingdom, such as installation, assembly, maintenance or training, in which case only that ancillary work is treated as arising in the Kingdom. Non-residents supplying goods to Saudi customers; relevant to how a project contract splits offshore supply from onshore works. Services performed in the Kingdom are treated as Saudi-source (Article 6).

    Zakat, Tax and Customs Authority (ZATCA) — Implementing Regulations of the Income Tax Law · Article 5(7) and Article 6 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Read from the Arabic text of the regulations, a scanned document with OCR errors; the English version was not compared. The Income Tax Law definition of a permanent establishment for construction and installation projects was not confirmed.

  24. The standard VAT rate is 15%. Taxable supplies in Saudi Arabia; zero-rating applies to certain exports, including services to non-resident customers.

    Zakat, Tax and Customs Authority (ZATCA) — Guideline for Regional Headquarters in KSA, Second Version, May 2026 · Section 4.3 VAT · In force from 1 July 2020 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The 1 July 2020 effective date of the increase from 5% to 15% comes from PwC Worldwide Tax Summaries (Corporate - Other taxes).

  25. The Foreign Trade and Payments Ordinance (AWV) sets authorisation requirements for exporting goods listed in Part I of the German Export List (Ausfuhrliste). National export controls; EU dual-use controls apply in addition and are not covered by this claim.

    Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) — Außenwirtschaftsverordnung (AWV) – Nichtamtliches Inhaltsverzeichnis · § 8 AWV heading: 'Genehmigungserfordernisse für die Ausfuhr von Gütern des Teils I der Ausfuhrliste' · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    Confirmed from the section heading in the official table of contents; the section text itself could not yet be checked because the fetch service was rate-limited.

  26. German bribery offences extend to bribery of foreign public officials, employees of international organisations and members of foreign and international courts. Applies §§ 331–334 StGB as specified in § 335a StGB.

    Bundesministerium der Justiz und für Verbraucherschutz / Bundesamt für Justiz (gesetze-im-internet.de) — § 335a StGB – Ausländische und internationale Bedienstete · § 335a(1) StGB · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  27. Government procurement is governed by the Government Tenders and Procurement Law, applies to procurement by government entities including procurement executed outside the Kingdom, and runs through the Etimad electronic portal. The Ministry of Finance sets procurement policy and maintains a boycott list.

    US Department of State — 2025 Investment Climate Statements: Saudi Arabia · Anti-Corruption: procurement · Checked 18 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary (foreign government) source; the official Saudi text could not yet be checked run.

  28. In Saudi government contracts, national products not on the mandatory list receive a price preference applied by treating the price of a competing foreign product as 10% higher than its bid price. Regulations on Preference for Local Content and Local SMEs and Companies Listed on the Capital Market in Business and Procurement Transactions, Article 10. Local SMEs receive a separate 10% price preference except in supply contracts and high-value contracts (Article 4(2)); for designated high-value contracts other than supply, price carries 60% of the financial evaluation and local content commitments and capital-market listing the remaining 40% (Article 17).

    Ministry of Finance — Regulations on Preference for Local Content and Local SMEs and Companies Listed on the Capital Market in Business and Procurement Transactions · Articles 4(2), 10 and 17 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The date of the version read was not confirmed; the Local Content and Government Procurement Authority (LCGPA) administers the local content portal.

  29. Under the Saudi Civil Transactions Law, agreed compensation is not payable if the debtor proves the creditor suffered no harm; the court may reduce it if it is excessive or the obligation was partly performed, and may increase it only where the debtor's fraud or gross negligence caused greater harm. Articles 178 and 179 of the Civil Transactions Law (Royal Decree No. M/191 of 1444H). Agreed compensation cannot be set for an obligation to pay a sum of money (Article 178).

    Gibson Dunn — Liquidated Damages Made Simple: What Saudi Arabia's Civil Transactions Law Says · Articles 178 and 179 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary (law firm) source dated May 2025; the official text on the Bureau of Experts portal could not yet be checked.

  30. The Commercial Courts Law of 2020 governs the specialised commercial courts, which hear commercial disputes, and the law encourages arbitration and mediation. Disputes between the government and private contractors generally go to the Board of Grievances.

    US Department of State — 2025 Investment Climate Statements: Saudi Arabia · Dispute Settlement: Legal System and Judicial Independence · In force from 1 January 2020 · Checked 18 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary (foreign government) source; the official Saudi text could not yet be checked run.

  31. German compulsory social insurance continues to apply to employees sent abroad from a German employment relationship where the posting is limited in time in advance, by the nature of the work or by contract (Ausstrahlung). Postings to countries with which Germany has no social security agreement are governed by this domestic rule; agreements or EU law take precedence where they apply.

    Federal Ministry of Justice (gesetze-im-internet.de) — Sozialgesetzbuch Viertes Buch (SGB IV) § 4 Ausstrahlung · § 4 Abs. 1 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  32. In 2026 German general pension insurance is 18.6% and unemployment insurance 2.6% of gross pay, each shared equally between employer and employee, on earnings up to EUR 8,450 a month. General pension insurance (not the miners' scheme, which has different rates and a EUR 10,400 ceiling).

    Deutsche Rentenversicherung — Die Sozialversicherungsrechengrößen 2026 · Beitragssätze and Beitragsbemessungsgrenzen 2026 · In force from 1 January 2026 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  33. A non-Saudi may not work in Saudi Arabia without a work permit, which requires legal entry and authorisation to work, skills the country needs, and a contract with an employer. All non-Saudi workers under the Labor Law.

    Ministry of Human Resources and Social Development (MHRSD) — Labor Law, Part Three: Employment of Non-Saudis · Article 33 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  34. Social insurance contributions for Saudi employees total 21.5% of salary (9.75% employee, 11.75% employer), while for non-Saudi employees the employer pays 2% for occupational hazards only, on salary capped at SAR 45,000 a month. Contribution base is basic salary plus housing allowance; rates as reported for employees covered before the new Social Insurance Law.

    PwC Worldwide Tax Summaries — Saudi Arabia: Corporate - Other taxes · Social insurance · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source. The GOSI website did not render content when opened. The new Social Insurance Law (understood to apply to new Saudi entrants from 3 July 2024 with phased pension contribution increases) is not reflected on the PwC page and was not confirmed on an official page.

  35. There is no personal income tax on employment income in Saudi Arabia. Individuals' employment earnings; social insurance contributions still apply.

    PwC Worldwide Tax Summaries — Saudi Arabia: Individual - Significant developments · Individual - Significant developments (last reviewed 29 July 2026) · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source.

  36. Under the Nitaqat programme, administered by the Ministry of Human Resources and Social Development, employers are placed in bands (Red, Low Green, Medium Green, High Green and Platinum) according to their Saudisation rate, and lower bands restrict new work visas and profession changes. Private-sector employers in Saudi Arabia. A procedural guide issued in May 2026 assesses Saudisation across all branches carrying out the same activity and replaces fixed percentage brackets with a formula under which required rates rise with headcount; thresholds vary by sector and are set for 2026 to 2028.

    Clyde & Co — Saudi Arabia's Developed Nitaqat Programme: Key updates from May 2026 · Article, June 2026 · Checked 19 October 2026 · Checked against a secondary source · Not yet professionally reviewed

    Secondary source; the MHRSD procedural guide itself could not yet be checked. Sector-specific percentages were not confirmed.

  37. Germany signed the New York Convention on 10 June 1958, ratified it on 30 June 1961 and it entered into force for Germany on 28 September 1961, without reservations or declarations. Recognition and enforcement of foreign arbitral awards.

    United Nations Commission on International Trade Law (UNCITRAL) — Status: Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) · Status table: Germany · In force from 28 September 1961 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

  38. The Germany–Saudi Arabia bilateral investment treaty, signed on 29 October 1996, has been in force since 8 January 1999. Protects qualifying German investments in Saudi Arabia and Saudi investments in Germany; the treaty text, including its dispute settlement clause, was not reviewed here.

    UNCTAD Investment Policy Hub — International Investment Agreements Navigator: Germany, bilateral investment treaties · Row: Germany - Saudi Arabia BIT (1996) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  39. Investors may transfer funds within or outside Saudi Arabia without delay, including profits and sale proceeds, in any recognised currency. Investors under the Investment Law; tax withholding on outbound payments still applies.

    Ministry of Investment (MISA) — Investment Law (official English translation, Bureau of Experts at the Council of Ministers) · Article 4(1)(d) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

  40. Saudi Arabia acceded to the New York Convention on 19 April 1994, with entry into force on 18 July 1994, and applies it only to awards made in the territory of another contracting state. Saudi Arabia has made no commercial-relationship declaration under the Convention.

    United Nations Commission on International Trade Law (UNCITRAL) — Status: Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) · Saudi Arabia entry, footnote (a) · In force from 18 July 1994 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

WONE Global Intelligence

Ask about this decision journey

Choose a question or ask your own. Answers draw on WONE Global's market guides and live official sources, and are set out in clear sections: the answer, the rules, the figures, what it means for you, the risks and who can help.

Intelligence windowLive official sources and WONE Global guides
Context

How answers are set out

  1. The direct answer
  2. The rules that apply, with their sources named
  3. Figures, rates and dates
  4. What it means for you, the risks and the next steps
  5. What is not confirmed, and who can help

Research, not legal or tax advice. Before acting, confirm with a qualified professional in each country involved. Sign in to save an answer.

Contact WONE Global

From options to a plan, coordinated on both sides.