SZTAC 46/2020/IR;IW/2018/1487 2
A taxpayer, a branch of a non-resident company head-quartered in Italy, appealed a decision by the Second Circuit of the First Instance Tax Zakat Objection Committee regarding a tax assessment by the GAZT.
Background
On 28/11/1441 AH, corresponding to 19/07/2020, the First Appellate Circuit of Income Tax Violations and Disputes convened at its headquarters in Riyadh to consider the appeal brought by a branch of a company on 10/08/1439 AH, corresponding to 26/04/2018. It challenged the Second Circuit of the First Instance Tax Zakat Objection Committee in Riyadh decision No. (17) of 1439 issued in Objection No. (30/38) filed by the appellant against the GAZT, in which the preliminary decision determined that:
First: To admit the objection submitted by a company’s branch.
Second: On merits:
1. To dismiss the taxpayer’s objection to withholding tax on technical services provided by the head office.
2. To settle the dispute regarding the income tax item on the unrealised currency differences profits.
3. To settle the dispute regarding the income tax item on withholding taxes recovered.
4. To dismiss the taxpayer’s objection to the social insurance difference clause.
5. To dismiss the taxpayer’s objection to the delay penalty item.