The new clause suggests that the supply of services to a customer without a place of residence in any Gulf Cooperation Council (GCC) Member State (currently any non-Saudi customer) would be zero-rated in cases when supply is based on facilitating the supply of taxable services by that non-resident customer to a person in Saudi Arabia. The change would call for Saudi companies involved in the supply of services to non-residents and those non-residents suffering from unrecoverable VAT costs to revisit the VAT treatment and, potentially, the business model of respective arrangements.
Source: KPMG
