In fiscal year 2021, Corporation A, which is a resident of Saudi Arabia, distributes dividends to its shareholder, Corporation S, which is a resident of Spain, has no PE in Saudi Arabia and has held a 20% participation interest in Corporation A since 2015.

Assuming that, according to Saudi Arabias domestic tax rules, a 5% withholding tax should apply to such outbound dividend, what would the Saudi Arabias tax treatment of such outbound dividend be?

		Saudi Arabia will levy a withholding tax whose rate will not exceed 10%
		Saudi Arabia will not levy any withholding tax
		Saudi Arabia will levy a 5% withholding tax
		Saudi Arabia will levy a withholding tax whose rate will not exceed 15%