Tax treaty between Ireland & Saudi Arabia: Effective from 1 January 2013

Signed in Riyadh on 19 October 2011, the tax agreement between Saudi Arabia and Ireland entered into force in December 2012 and is effective from 1 January 2013.

The main provisions are as follows.

Permanent establishment

The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

The term "permanent establishment" also includes:

• a building site, a construction, assembly or installation project, or supervisory activities, in connection therewith, but only where such site, project or activities continue for a period more than 6 months;

• the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within a contracting state for a period or periods aggregating more than 6 months within any 12-month period.

Dividends