Key Points of the Tax Convention between the Government of Japan and the Saudi Arabia

[Provisional translation]

1. Provisions concerning business profits resulting from business activities
   When an enterprise establishes a permanent establishment (branch, etc.) in the partner country and conducts business activities, only business profits resulting from business activities carried out through the permanent establishment is to be subject to tax in the said country.
2. Provisions to reduce taxation on investment income in the source country
   Taxation on investment income (dividends, income from debt-claims (interest) and royalties) in the source country is reduced as follows.

   Dividends		Income from debt-claims (Interest)	Royalties
   Between parent and subsidiary (Shareholding requirement)	Others
   5% (at least 10%)	10%	Exemption (government, etc.) 10% (others)	5% (Use of equipment) 10% (others)

3. Provisions concerning dispute resolution between the tax authorities of the two countries
   If a taxpayer considers that any tax imposed on him/her is not in accordance with the provisions of the Convention, he/she may request for dispute resolution between the tax authorities (mutual agreement procedure).
4. Provisions concerning exchange of Information between the tax authorities of the two countries
   The Convention enables the tax authorities of the two countries to exchange information regarding tax matters.