In February 2021, the Government of the Kingdom of Saudi Arabia announced its plans to limit the awarding of contracts to foreign multinational enterprises that do not have a regional headquarters set-up in the country. In December 2023, the Saudi Arabia Ministry of Investment in coordination with Ministry of Finance and the tax authorities announced a 30-year incentive plan for Saudi Arabia Regional Headquarters, which includes inter alia 0% corporate income tax and withholding taxes for the entire period. In February 2024, the tax authorities provided more clarifications about the conditions to obtain the benefits of the new regime. These also include the need to comply with the arm’s length principle and transfer pricing rules, which raises interesting questions from a tax technical point of view considering the particularities of the Saudi Arabia Regional Headquarters regime.