Pillar guide · Updated 20 June 2026
The Saudi RHQ programme is the single most consequential incentive for multinationals operating in MENA. Companies that move their regional command to Riyadh receive a 30-year corporate tax holiday and become eligible to bid for a USD 35bn+ Saudi government procurement pipeline. This is the operational playbook our incorporation desk uses on RHQ filings.
Launched in 2021 and made binding in January 2024, the Regional Headquarters programme is a special MISA licence category. RHQ-licensed companies must base their regional management team in Riyadh, manage operations in at least three MENA countries from KSA, and hire 15+ executives in year one (rising to 35 by year five).
In return: 30 years of zero corporate income tax on qualifying RHQ income, 30 years of zero withholding tax on RHQ dividends and services to affiliates, no Saudization quota in year one, accelerated MISA approvals for sister entities, and — most importantly — eligibility for Saudi government tenders worth tens of billions annually.
From 1 January 2024, no foreign company without an active Saudi RHQ licence can win Saudi government contracts above SAR 1m. The rule applies to direct contracts, sub-contracts where a Saudi government entity is the ultimate beneficiary, and PIF-funded mega-project bids. Companies generating ‘material’ MENA revenue from Saudi public-sector work are effectively required to file an RHQ.
Narrow exemptions exist: companies in specific defence partnerships, certain humanitarian organisations, and a transitional grace for in-flight projects. Tamra's tax desk maps each multinational's revenue exposure to determine RHQ urgency.
MISA publishes a list of ‘strategic and management’ activities permitted under the RHQ licence — strategic direction, business planning, regional accounting and consolidated reporting, treasury, IP licensing, regional sales coordination, supply-chain management, R&D, marketing, brand management, regional HR, internal audit, IT, training, and shared services to affiliates.
Trading, manufacturing, and consumer-facing operations cannot sit under the RHQ — those go under a separate LLC. Most multinationals run the RHQ alongside an operating LLC; the RHQ handles regional management, the LLC handles Saudi-market revenue.
Step 1: confirm the parent company meets RHQ eligibility — multinational presence in at least two non-Saudi countries, audited consolidated financials, and a board mandate authorising the regional command move.
Step 2: Tamra files the RHQ MISA application with the parent's board resolution, regional org chart showing the executives moving, and a three-year operating plan against the 35-executive headcount target.
Step 3: MISA reviews in 5–15 working days. Step 4: Commercial Registration issued at Ministry of Commerce. Step 5: Qiwa, GOSI, ZATCA, and Mudad enrolments. Step 6: 15+ executives sponsored, Iqamas issued, Riyadh office leased on Ejar.
The 30-year holiday is structured as two separate exemptions confirmed by ZATCA in May 2024: 0% corporate income tax on RHQ-qualifying revenue (intra-group management fees, regional support services), and 0% withholding tax on dividends paid by the RHQ to affiliates outside KSA.
Practical impact: an RHQ that bills affiliates SAR 200m in regional management fees keeps the full SAR 200m versus the SAR 50m corporate tax burden it would pay under a normal LLC. The exemption requires substance — the RHQ must employ the headcount, the executives must be Saudi-resident, and the work must demonstrably be performed from KSA.
The RHQ licence is reviewed annually by MISA. The entity must demonstrate: 15 executives in year one and 35 by year five (with at least one C-level role and one regional MD), authentic decision-making housed in Riyadh, audited financials showing the qualifying revenue mix, and CSR / Saudization commitments.
Failure to maintain substance triggers loss of the tax holiday retroactively — ZATCA may reassess prior years. Tamra runs a quarterly RHQ compliance dashboard for managed clients so the headcount, payroll, and decision-making evidence is always audit-ready.
The 30-year tax holiday is conditional on the RHQ exercising real management substance from Riyadh. ZATCA's 2024 guidance defines substance across four axes: people (the 15+ executives must be Iqama-resident in Saudi Arabia and on Mudad payroll), premises (a leased, named office in Riyadh — not a shared desk), decisions (board minutes and decision logs must originate in Riyadh), and expenditure (qualifying activities must generate a proportionate cost base inside the RHQ).
Failing any of these triggers a re-classification of RHQ revenue as ordinary LLC income — taxed at 20% retrospectively plus 1% per month late-payment surcharge. Tamra's RHQ compliance desk runs quarterly substance evidence packs covering Mudad payroll exports, executive Iqama validity, board minutes, and Riyadh cost allocations.
Because the RHQ can only invoice qualifying intra-group activities, multinationals run a twin-entity structure: the RHQ handles regional management and bills affiliates under cost-plus arrangements; a separate Saudi LLC handles Saudi-market customer revenue at the standard 20% corporate rate. Both share the same office and many of the same people, but contracts, cost pools, and ZATCA returns are kept legally distinct.
Transfer-pricing between the two is heavily scrutinised. Most clients adopt OECD-aligned cost-plus 5–10% on the RHQ's intra-group services and an arms-length royalty for shared IP. Documentation must be ready before the first ZATCA return; retroactive transfer-pricing files are the most common ZATCA challenge in 2026.
The headcount target is operationally harder than the licence itself. The 15 executives must be Iqama-resident, which means relocating spouses and children, finding schools (Riyadh international school waitlists currently run 6–12 months), securing housing in the western or northern Riyadh corridors, and shipping personal effects through Saudi customs.
Compensation packages typically run 1.3–1.8× home-country base to clear the relocation friction. Tax equalisation is largely unnecessary — Saudi Arabia has no personal income tax — but employer-funded housing, schooling, and one annual home-leave trip have become market-standard for executive relocations. Tamra's mobility desk runs the visa, Iqama, family Iqama, school admission, and housing search as a co-ordinated executive relocation package.
The year-one headcount is 15; the year-five target is 35. The interim ramp (years two through four) is where most RHQ programmes overspend. The MISA framework allows flexibility on the role mix, so the staging plan typically pulls regional functions (treasury, IP, internal audit, shared services) from sister entities rather than net-new hires — moving headcount inside the group rather than adding cost.
Tamra's RHQ workforce-planning model maps the executive ramp against the group's existing MENA org chart, identifies functions that can re-base to Riyadh with minimal cost (typically regional finance, IP holding, and treasury), and stages the relocations across the five years to smooth the executive-housing and school-placement load.
| Item | Cost (SAR) | Notes |
|---|---|---|
| MISA RHQ licence | 12,000 first year, 60,000 from year 2 | Same fee schedule as standard MISA |
| Commercial Registration | 1,200 (5 years) | Issued post-MISA |
| Riyadh office (1,000 m²) | 600,000–1,200,000 | Annual; Class-A market rates |
| 15 executive Iqamas + visas | ~250,000–400,000 | Includes labour levy and CCHI insurance |
| Tamra RHQ incorporation | ~60,000 | One-off; includes substance audit and HR rollout |
Excludes executive compensation, Saudization-protective Saudi hires, and Riyadh relocation packages.
Yes, if annual Saudi government revenue exceeds SAR 1 million or you want to bid on PIF-funded contracts. The rule has applied since 1 January 2024 and narrow exemptions exist for defence and humanitarian work.
Strategic and management functions: regional strategy, planning, treasury, IP, shared services, HR, IT, R&D, marketing, supply chain coordination. Trading, manufacturing, and direct Saudi customer sales must sit under a separate operating LLC.
Zero corporate income tax on qualifying RHQ revenue (intra-group management fees and regional services) plus zero withholding tax on dividends/services paid by the RHQ to non-Saudi affiliates. Confirmed by ZATCA in May 2024.
15 executives by end of year one, rising to 35 by year five. At least one C-level executive and one regional MD must be among them, and at least one strategic decision-making function (e.g. regional CFO, COO) must be exercised from Riyadh.
No — the RHQ is a separate MISA licence category. Multinationals typically run the RHQ alongside the operating LLC. Tamra commonly converts the existing entity's regional management functions into the RHQ and leaves trading under the LLC.
Yes — the licence specifies Riyadh as the operational seat. Branches or shared-service centres elsewhere in KSA are permitted but the decision-making centre and qualifying-activity headcount must be in Riyadh.
12–18 weeks on Tamra-managed files: 5 weeks to MISA approval, 4 weeks for CR and portal enrolments, 6–10 weeks to land the first 15 executives. The bottleneck is usually the executive relocations, not the licence itself.
MISA flags non-compliance at the annual review. If substance is missing, the tax holiday can be reassessed by ZATCA for prior years. Tamra runs quarterly substance reports against headcount, payroll on Mudad, and executive Iqama validity.
Local Saudi-market revenue cannot legally sit under the RHQ. It must be invoiced from a separate operating LLC and is taxed at the standard 20% corporate rate. ZATCA's transfer-pricing rules apply between the RHQ and the LLC.
No — the RHQ requires demonstrable multinational presence (registered operating entities in at least two non-Saudi countries) plus regional mandate across at least three MENA markets. Tamra's eligibility diagnostic confirms this before MISA is filed.
Our Riyadh team handles the live filings every day.
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