This journey assumes
- The US parent is a US C-corporation and the RHQ will be a Saudi entity owned by it (directly or through the US group).
- The RHQ will manage and provide services to group companies in the region; its own trading or project income, if any, is incidental.
- The group sells, or wants to sell, to Saudi government agencies.
- Most senior RHQ staff will be expatriates, some moving from the US, with Saudi hires building up over time.
- Rules are stated as at 19 October 2026; there is no US-Saudi income tax treaty or totalisation agreement.
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.
Registering the RHQ and meeting programme conditions
The US company registers with the Ministry of Investment and obtains an RHQ licence, then must start mandatory activities within six months, at least three optional activities and 15 full-time staff within a year, and meet ZATCA's substance tests. Being an RHQ matters commercially because Saudi government agencies generally may not contract with foreign companies that have no RHQ in the Kingdom.
- The US parent's commercial registration and last year's financial statements must be certified or authenticated by the Saudi Embassy for investment registration; both countries are parties to the Apostille Convention, which ZATCA accepts for treaty forms.12
- The US board should approve the RHQ mandate, its budget for at least 15 full-time staff in the first year and the delegation of regional management to Riyadh, because the Saudi substance tests require real decision-making there.34
- A foreign investor must register with the Ministry of Investment before investing; the Saudi entity is then incorporated, commonly as an LLC, through the Saudi Business Center, which opens its files with the labour ministry, ZATCA and social insurance.567
- An RHQ must start its mandatory activities within six months of its licence, start at least three optional activities within a year and employ at least 15 full-time employees within a year.3
- ZATCA's substance conditions include a physical office, board meetings held physically in the Kingdom, at least one Saudi-resident director and at least three staff at executive director, vice president or director level; unremedied violations carry SAR 100,000 fines (SAR 400,000 on repeat) and possible suspension of incentives.48
- From 1 January 2024 Saudi government agencies may not contract with foreign companies that have no RHQ in the Kingdom, or their related parties, subject to exceptions such as contracts below SAR 1 million.9
Saudi tax, the RHQ incentive and the absence of a treaty
A licensed RHQ pays 0% income tax on eligible RHQ activities and 0% withholding tax on qualifying payments for 30 years, but other income is taxed at the normal 20%. There is no US-Saudi income tax treaty, so Saudi domestic withholding rates apply in full to payments that fall outside the RHQ incentive, and the US 21% federal rate applies to the parent.
- The IRS list of US income tax treaties does not include Saudi Arabia, so no treaty reduces Saudi withholding on payments to the US or US tax on Saudi income.10
- The US parent pays federal corporate tax at 21%; dividends from the RHQ are generally eligible for the section 245A deduction for the foreign-source portion.1112
- A licensed RHQ meeting ZATCA's conditions pays 0% income tax on eligible activities and 0% withholding tax on qualifying payments to non-residents for a renewable 30 years from licence.13
- Income from activities that are not eligible RHQ activities is taxed at 20%, so any sales, project or non-qualifying service income in the RHQ needs separate tracking.1415
- Outside the incentive, Saudi withholding is 5% on dividends and loan charges, 15% on royalties and 20% on management fees paid to non-residents, with no treaty relief available for US recipients.1617
- Related-party transactions must be at arm's length and documented for ZATCA, and VAT is charged at 15%.1819
US tax on a low-taxed Saudi RHQ and US reporting
A 0%-taxed RHQ owned by a US company is a controlled foreign corporation whose income can be taxed in the US currently, through net CFC tested income or subpart F foreign base company services income, because the high-tax exception cannot apply at 0%. The US parent also files Form 5471, possibly Form 8975, and FBAR.
- From 2026 each US shareholder of a CFC includes its net CFC tested income (formerly GILTI) in income, with a 40% section 250 deduction for a domestic corporation.2021
- Fees an RHQ earns for managerial, technical and similar services to related companies outside Saudi Arabia can be foreign base company services income, and the high-tax exclusion needs a foreign effective rate above 90% of the US maximum rate, which a 0% RHQ cannot meet.2223
- The US parent files Form 5471 for the RHQ, Form 8975 country-by-country reporting if the group is in scope, and FBAR where Saudi accounts it has an interest in or signature authority over exceed USD 10,000 in aggregate.242526
- Under the OECD side-by-side package, top-up tax for IIR and UTPR purposes is deemed zero for groups headquartered in the United States, but qualified domestic minimum top-up taxes still apply to local subsidiaries of US-parented groups; whether Saudi Arabia applies such a tax to an RHQ was not confirmed here.2728
- Keeping the RHQ's substance in Riyadh supports both the Saudi incentive and the US position that the services are genuinely performed by the RHQ.4
Staff, permits, Saudisation and social security
Foreign staff need Saudi work permits sponsored by the RHQ entity, and the employer is placed in a Nitaqat band by its Saudisation rate. There is no personal income tax on salaries in Saudi Arabia and only a 2% employer contribution for non-Saudis, but there is no US-Saudi totalisation agreement, so US social security questions remain for US staff.
- The Social Security Administration's totalisation list does not include Saudi Arabia, so there is no certificate of coverage route for US staff sent to Riyadh.29
- Salary and secondment recharges between the US parent and the RHQ are related-party transactions to be priced at arm's length in Saudi Arabia.18
- A non-Saudi may not work without a work permit, which requires legal entry, needed skills and a contract with a Saudi employer.30
- Nitaqat places employers in bands by Saudisation rate, and lower bands restrict new work visas, which matters as the RHQ grows towards and beyond 15 staff.31
- Social insurance for non-Saudi employees is a 2% employer contribution for occupational hazards (21.5% in total for Saudi employees), and there is no personal income tax on employment income.3233
Money, compliance and disputes
Saudi Arabia does not limit remittances of profits or capital, and the riyal has been fixed at 3.75 to the US dollar since 1986. US anti-bribery and sanctions laws follow the US parent into Saudi Arabia. Both countries apply the New York Convention, which matters because there is no US-Saudi investment treaty that this research could confirm and Saudi consent to ICSID is case by case.
- The FCPA applies to US persons, so the RHQ's dealings with Saudi officials, including in government procurement, fall within the US parent's anti-bribery controls.34
- OFAC sanctions apply to the US group's regional activity managed from Riyadh, which matters for an RHQ covering neighbouring markets.35
- The US applies the New York Convention to awards made in other contracting states and to commercial relationships, so awards made in Saudi Arabia under commercial contracts can be enforced in the US.36
- Saudi Arabia does not limit remittances of profits, capital or returns on intellectual property apart from withholding taxes, and the riyal is fixed at 3.75 per US dollar.3738
- Saudi Arabia is a New York Convention party for awards made in other contracting states; it is an ICSID member but has not given general consent, so investment arbitration needs case-by-case consent.3940
Structures to consider
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
- United StatesUS board approves the RHQ mandate, regional scope, budget and senior appointments in Riyadh.
- United StatesModel US tax on a 0%-taxed RHQ (net CFC tested income, subpart F services income, section 245A) and decide which entities the RHQ will serve and charge.After step 1
- United StatesPrepare the US parent's commercial registration and financial statements, certified or authenticated for Saudi use.After step 1
- Saudi ArabiaRegister with the Ministry of Investment and apply for the RHQ licence.After step 3
- Saudi ArabiaIncorporate the Saudi entity through the Saudi Business Center, which opens its labour, ZATCA and social insurance files.After step 4
- Saudi ArabiaSecure a physical office, appoint a Saudi-resident director and arrange for board meetings to be held in the Kingdom.After step 5
- Saudi ArabiaHire senior staff and obtain work permits; manage the Nitaqat band from the start.After step 5, 6
- Saudi ArabiaStart mandatory RHQ activities within six months of the licence.After step 6, 7
- Both sidesPut intercompany service and cost-sharing agreements in place for the regional companies, with arm's length pricing and ZATCA documentation.After step 2, 5
- Saudi ArabiaWithin one year: at least three optional activities and 15 full-time employees.After step 8
- United StatesUS reporting: Form 5471, any Form 8975 and FBAR for Saudi accounts where thresholds are met.After step 5
- Both sidesOngoing: substance reviews, separate tracking of non-eligible income taxed at 20%, VAT, and US annual inclusions.After step 9, 10, 11
What we need from you before anyone can advise
- Which regional companies the RHQ will manage and which services it will charge them for.
- Whether the RHQ will earn any income from activities outside the eligible RHQ list (sales, projects, Saudi customers).
- Planned headcount by year, the mix of Saudi and expatriate staff, and who will be the Saudi-resident director.
- Whether the group's revenue brings it within Pillar Two or US country-by-country reporting.
- How many US staff will move to Riyadh, for how long, and whether they stay on US payroll.
- Expected Saudi government contracts and their values.
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- New source pages could not yet be checked: web search budget was exhausted and the page fetch service was rate limited, including the ZATCA RHQ guideline, the MISA investor guide and the US State Department investment climate statement for Saudi Arabia. All claims are reused source-checked claims from existing records.
- The full list of mandatory and optional RHQ activities, the legal form an RHQ may take (branch of the foreign company or a company) and the RHQ licence documents were not confirmed.
- Non-tax RHQ incentives such as visa facilitation or Saudisation exemptions were not confirmed.
- Whether a US-Saudi bilateral investment treaty or a trade and investment framework agreement exists, and whether any free trade agreement applies, was not confirmed; BEA survey obligations of the US parent were not covered.
- Whether Saudi Arabia applies a qualified domestic minimum top-up tax, and how it treats RHQ income, was not confirmed.
- US antiboycott rules (Export Administration Regulations Part 760 and the IRS boycott reporting regime) were not researched; they can apply to US companies operating in the region.
- US treatment if the RHQ is a branch rather than a company (for example Form 8858) and entity classification elections were not researched.
- How Saudi withholding applies to payments from group companies elsewhere in the region to the RHQ, and under those countries' treaties with Saudi Arabia, was not researched.
- Visa routes and costs for US staff moving to Riyadh and the US tax position of those individuals 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.
- Saudi corporate adviser: what legal form and documents does MISA require for our RHQ licence, and which of our planned activities count as mandatory and optional RHQ activities?
- Saudi tax adviser: which of our RHQ income will be eligible for the 0% rate, how should we track non-eligible income, and how will ZATCA test our substance?
- US tax adviser: will our RHQ's service fees be foreign base company services income or net CFC tested income, and what US tax will arise each year?
- US tax adviser: are dividends from the RHQ eligible for the section 245A deduction, and what US filings (5471, 8975, FBAR, BEA surveys) apply?
- Pillar Two adviser: does Saudi Arabia apply a domestic minimum top-up tax to RHQs, and how does the side-by-side package affect our group?
- Saudi employment adviser: how will Nitaqat apply as we hire, and what are the work permit steps for our senior staff?
- US payroll adviser: how should we handle US social security for US staff sent to Riyadh, given there is no totalisation agreement?
- Saudi procurement counsel: which of our planned government contracts depend on our RHQ status, and do any exceptions apply?
Who can help, on each side
United States
- Setting up and running a company · Arranged by WONE Global on request
- Licences, permits and regulators · Arranged by WONE Global on request
- Tax and structuring · Led by F Miles Adler
- Accounting and annual filings · Arranged by WONE Global on request
- Employment, payroll and immigration · Arranged by WONE Global on request
- Banking and capital · Arranged by WONE Global on request
- Anti-bribery, sanctions and compliance · Arranged by WONE Global on request
- Disputes and arbitration · Arranged by WONE Global on request
Saudi Arabia
- Setting up and running a company · Arranged by WONE Global on request
- Licences, permits and regulators · Arranged by WONE Global on request
- Tax and structuring · Led by Abdullah Yousef Alhussaini
- Accounting and annual filings · Led by Abdullah Yousef Alhussaini
- Employment, payroll and immigration · Arranged by WONE Global on request
- Banking and capital · Arranged by WONE Global on request
- Anti-bribery, sanctions and compliance · Led by Abdulrahim bin Saleh Al-Zahrani
- Disputes and arbitration · Led by Abdulrahim bin Saleh Al-Zahrani
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.
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.
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.
The status table listed 130 contracting parties when checked.
A regional headquarters must start its mandatory activities within six months of its licence, start at least three optional activities within one year, and employ at least 15 full-time employees within one year. Regional headquarters registered with the Ministry of Investment.
Under ZATCA's regional headquarters tax guideline, a regional headquarters must among other substance conditions have a physical office in the Kingdom, hold board meetings physically in the Kingdom, have at least one director resident in the Kingdom, and employ at least three staff at executive director, vice president or director level. Applies to RHQs licensed by MISA claiming the RHQ tax incentives. Guideline second version, May 2026; the Arabic version prevails.
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.
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.
On incorporation through the Saudi Business Center, the company's file is opened with the Ministry of Human Resources and Social Development and the company is registered with ZATCA, social insurance, the Saudi Post national address service and the chamber of commerce. Outputs of the Ministry of Commerce LLC incorporation service.
Regional headquarters economic substance violations carry a SAR 100,000 fine if not remedied within 90 days and SAR 400,000 for repeat violations, and incentives may be suspended. Licensed RHQs claiming tax incentives.
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.
Secondary source (law-firm briefing, January 2023). No official Saudi page stating the contracting rule was found; the Ministry of Investment investor guide (2026) describes the RHQ licence but not the contracting restriction. Thresholds and exceptions may have been revised since.
The IRS list of US income tax treaties includes India, the United Kingdom, Germany and France, but not the UAE, Saudi Arabia or Singapore. Comprehensive income tax treaties listed by the IRS.
US corporations figure federal income tax by multiplying taxable income by 21%. Federal corporate income tax. State and local corporate income or franchise taxes are additional and vary by state.
A domestic corporation that is a United States shareholder of a specified 10-percent owned foreign corporation may deduct the foreign-source portion of dividends received from it. Federal, 26 USC 245A(a). Does not apply to hybrid dividends (245A(e)), where the foreign company obtained a deduction or other tax benefit for the payment. Holding period and foreign tax credit interactions could not yet be checked.
A licensed regional headquarters pays 0% income tax on income from eligible activities and 0% withholding tax on qualifying payments to non-residents for a renewable period of 30 years from the licence date. RHQ licensed by the Ministry of Investment that meets ZATCA's conditions and economic substance requirements; non-qualifying income is taxed at 20%.
The 16 February 2024 effective date of the RHQ tax rules comes from PwC Worldwide Tax Summaries (Significant developments).
Income of a regional headquarters from activities that are not eligible RHQ activities is taxed under the normal rules, at 20% of the tax base, and does not benefit from the RHQ incentive. ZATCA gives as an example an RHQ distributing products in the Kingdom for an affiliate, which it treats as an ineligible activity; the incentive can also be revoked for misuse.
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.
Secondary source; ZATCA pages not yet checked for this point.
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.
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.
Related-party transactions must follow the arm's length principle, with supporting documentation submitted to ZATCA. Taxpayers with related-party transactions; documentation thresholds were not confirmed.
Stated in the RHQ guideline. Article 10(11) of the Income Tax Implementing Regulations also disallows related-party charges above independent-party prices.
The standard VAT rate is 15%. Taxable supplies in Saudi Arabia; zero-rating applies to certain exports, including services to non-resident customers.
The 1 July 2020 effective date of the increase from 5% to 15% comes from PwC Worldwide Tax Summaries (Corporate - Other taxes).
For taxable years beginning after 31 December 2025, each United States shareholder of a controlled foreign corporation must include its net CFC tested income in gross income; Public Law 119-21 renamed this inclusion from global intangible low-taxed income (GILTI). Federal, 26 USC 951A as amended by Pub. L. 119-21, section 70323. Applies to US shareholders (generally 10% owners) of controlled foreign corporations.
For taxable years beginning after 31 December 2025, a domestic corporation may deduct 40% of its net CFC tested income amount (with the related section 78 amount), reduced from 50%, and 33.34% of its foreign-derived deduction eligible income, reduced from 37.5%. Federal, 26 USC 250(a)(1) as amended by Pub. L. 119-21, section 70321.
Foreign base company services income of a controlled foreign corporation includes income from technical, managerial, engineering and similar services performed for or on behalf of a related person outside the country under whose laws the corporation is organised. Federal, 26 USC 954(e)(1). A Panama hub serving group companies in other countries is the typical case.
Income is excluded from foreign base company income only if it was subject to foreign income tax at an effective rate greater than 90% of the maximum US corporate rate in section 11. Federal, 26 USC 954(b)(4). With the 21% federal rate this means an effective foreign rate above 18.9%.
The 18.9% figure is arithmetic from the 21% rate in IRS Publication 542, not a figure stated on the page.
Certain US persons who are officers, directors or shareholders of certain foreign corporations must file Form 5471 and its schedules to meet the reporting requirements of sections 6038 and 6046 of the Internal Revenue Code. Federal. Current instructions are dated December 2025 (page updated 17 September 2026). The filer categories that apply to a US parent corporation are set out in the instructions, which could not yet be checked in full.
US-parented multinational groups report country-by-country information to the IRS on Form 8975 and its Schedule A. US federal; the revenue threshold is not stated on this IRS page.
A US person, including a corporation, partnership or LLC, with a financial interest in or signature authority over foreign financial accounts whose combined value exceeds 10,000 US dollars at any time in the calendar year must file FinCEN Form 114 (FBAR) electronically, due 15 April of the following year with an automatic extension to 15 October. Federal. Applies to a US subsidiary that holds accounts abroad, for example with its foreign parent's bank.
The OECD/G20 Inclusive Framework released a side-by-side package on 5 January 2026 under which top-up tax is deemed zero for IIR and UTPR purposes for groups headquartered in a jurisdiction with a qualified side-by-side regime, effective for fiscal years beginning on or after 1 January 2026; the United States is currently the only jurisdiction listed. Elective safe harbour; group must meet eligibility criteria. It follows the G7 statement of June 2025.
Secondary source: the OECD release itself could not yet be checked (search budget exhausted and OECD topic page did not carry the detail). Confirm against the OECD Inclusive Framework publication of 5 January 2026.
Under the side-by-side package, qualified domestic minimum top-up taxes and GloBE Information Return obligations continue to apply, including to local subsidiaries of US-parented groups. Relief covers the IIR and UTPR only.
Secondary source; confirm against the OECD publication.
The Social Security Administration lists totalisation agreements with 31 countries, including France, Germany and the United Kingdom; India, the UAE, Saudi Arabia and Singapore are not among them. Federal. SSA keeps a separate status page with agreements in force; that page could not yet be checked.
An IRS page on totalisation agreements still refers to 25 countries; the SSA list is more recent.
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.
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.
Secondary source; the MHRSD procedural guide itself could not yet be checked. Sector-specific percentages were not confirmed.
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.
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.
There is no personal income tax on employment income in Saudi Arabia. Individuals' employment earnings; social insurance contributions still apply.
Secondary source. Reused from market guide claim sa-people-014.
The FCPA anti-bribery provisions make it unlawful to corruptly offer, pay, promise or authorise anything of value to a foreign official to obtain or retain business, and apply to all US persons and certain foreign issuers of securities and, since 1998, to foreign firms and persons who cause an act in furtherance of a corrupt payment within US territory. Federal. The Foreign Extortion Prevention Act of July 2024 separately makes it a crime for a foreign official to demand or accept such payments from issuers, domestic concerns and others, with up to 15 years' imprisonment.
The Office of Foreign Assets Control (OFAC), part of the US Treasury, administers and enforces US economic and trade sanctions, using asset blocking and trade restrictions against targeted countries, regimes and persons. Federal. Programmes include Russia-related, Iran, North Korea, Cuba, Venezuela-related, counter-narcotics and cyber-related sanctions.
The United States acceded to the New York Convention on 30 September 1970, effective 29 December 1970, applying it only to awards made in another contracting state and only to commercial relationships. Federal; reciprocity and commercial reservations.
Saudi Arabia does not limit remittances of profits, debt service, capital, capital gains, returns on intellectual property or payments for imported inputs, other than certain withholding taxes, and there are no waiting periods for remitting investment returns through normal legal channels.
Secondary (foreign government) source; consistent with Article 4 of the Investment Law (claim sa-banking-001).
SAMA has fixed the official exchange rate at 3.75 Saudi riyals per US dollar since 1986, and commercial transactions commonly reflect the official rate.
Secondary (foreign government) source; SAMA's own statement of exchange-rate policy could not yet be checked. Year only.
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.
Saudi Arabia is a member of ICSID but has not given general consent to refer investment disputes to ICSID; consent is required case by case. Saudi Arabia has bilateral investment treaties with investor-state arbitration clauses, including with France, Spain, China and Japan.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. The ICSID member-state database could not yet be checked.
