Saudi Arabia's Regional Headquarters Programme: Who Actually Moved, and What They Got

Saudi Arabia’s regional headquarters programme is a procurement rule wearing a tax incentive as a disguise. Since 1 January 2024, a foreign company without a licensed regional headquarters in the Kingdom cannot be awarded a central-government or state-entity contract worth more than SAR1m ($266,000) [S8][S9]. Companies that comply receive a 30-year 0% corporate income tax and withholding tax package and a 10-year exemption from Saudisation quotas [S3][S4][S6]. As of the first quarter of 2026, more than 780 international firms held RHQ status — against an original Vision 2030 target of 480 by 2030 [S15][S18]. It is also one of the sharper instruments in the documented pulling-apart of Riyadh and Abu Dhabi.

That is the entire mechanism, and it has worked on its own terms: the target was passed during 2024, six years early. What the programme has not produced is evidence about depth. The Ministry of Investment (MISA) publishes a licence count, not headcount, floor space, payroll or an operational-status register. The number quoted is the numerator; the denominator has never been released.

Last verified: 31 July 2026.

This article is legal and tax information, not advice. Rules change and apply differently to different structures; confirm your position with MISA, ZATCA or licensed counsel before acting.

What is Saudi Arabia’s regional headquarters programme?

The Saudi Arabia regional headquarters programme is a licensing scheme run jointly by the Ministry of Investment and the Royal Commission for Riyadh City, authorising a multinational group to operate a MENA-wide administrative centre from the Kingdom [S1]. The licence is not a trading permit: an RHQ is barred from revenue-generating commercial activity itself, and the group’s commercial operations must sit in separately licensed affiliates [S7].

It was announced in February 2021. By June 2023 the Atlantic Council recorded 80 licences issued against a target of 480 companies by 2030, and supplied the baseline the policy was designed to attack: the UAE hosted regional headquarters for 76% of companies on the Forbes Middle East list, while Saudi Arabia — with roughly twice the GDP — hosted under 5% as of 2021 [S18].

The programme has two distinct instruments, and confusing them is the commonest error in coverage. The procurement rule is the stick, applying to every eligible foreign company doing state business; the incentive package is the carrot, applying only to firms that take a licence. A company can be caught by the first without benefiting from the second. See also the Saudi Arabia market entry guide and company formation.

Do I need an RHQ to bid for Saudi government contracts?

Yes, above SAR1m. From 1 January 2024, Saudi government entities and state-linked bodies were instructed not to contract with foreign companies whose regional headquarters sit outside the Kingdom, where the contract value exceeds SAR1m ($266,000) [S8]. AGBI reported the threshold on 3 January 2024, the week the rule took effect — it was part of the original design, not a later softening.

Three carve-outs existed from the start or shortly after. Contracts at or below SAR1m fall outside the rule. Work performed outside the Kingdom is exempt [S10]. And the Ministry of Finance circulated a non-compliance list to government entities alongside a process for exempting cases where no compliant supplier existed [S23].

The rule was not delayed and the commencement date held. What changed came 23 months later. In November 2025, the Local Content and Government Procurement Authority launched a formal exemption service on Etimad, the Ministry of Finance procurement platform. A government entity may now apply, before issuing a tender, to contract with a non-RHQ supplier where either only one technically compliant bid is received, or the non-RHQ bid ranks technically among the best and is at least 25% cheaper than the second-best offer. Approvals can cover one project, a group of projects, or a defined period [S9][S10].

The 25% price test changes the rule’s character. The original proposition was binary: hold a licence or lose the business. The revised one is that a non-RHQ bidder must be materially cheaper to win. Nazar Musa, chief executive of PRO Partner Group, put the effect plainly in January 2024, before the exemption existed: if one company bids 100 and another bids 74, “the next conversation will be with company A” [S8]. Since November 2025 that conversation has a formal route.

For procurement beyond the RHQ gate, see Saudi procurement and supplier access and the government contracts guide.

What tax incentives does an RHQ get?

A 0% rate on two taxes for 30 years. The package was announced on 5 December 2023 by MISA with the Ministry of Finance and the Zakat, Tax and Customs Authority (ZATCA), which issued the implementing Tax Rules in February 2024 [S3][S4][S5][S24].

What the relief does not cover. Zakat, the 15% value-added tax and real estate transaction tax continue to apply [S5][S6] — which matters for any group with GCC or Saudi shareholders, since zakat may be the operative charge on part of the profit. See Saudi Arabia’s corporate tax rate and the taxation overview.

A figure conflict worth resolving. The Invest Saudi programme page states that an RHQ receives 250 work visas automatically from day one [S1]; DLA Piper’s February 2024 summary described RHQs as able to obtain “an unlimited number of visas” [S6]. The programme’s own page is the more authoritative statement of what is granted at licensing, and the “unlimited” framing reflects how the package was marketed at launch. Treat 250 as the day-one allocation and further quota as an application, not an entitlement.

How long does the 30-year exemption last?

Thirty years from the date the licence is granted, or until the entity ceases to qualify, whichever comes first — and renewable [S5][S6]. The clock starts at licensing, not when the office becomes operational, which quietly rewards early filing.

ZATCA attached nine economic-substance conditions [S4]: a valid MISA licence covering at least three elective activities; a physical Saudi office; activities conducted and managed in the Kingdom, with board meetings held there; operating expenditure matching that activity; revenue from eligible activities; separate books for non-eligible activity; at least one Kingdom-resident executive; adequate full-time staff; and related-party transactions priced at arm’s length under the Transfer Pricing Bylaws.

That last condition is the enforcement hook that gets least attention. An RHQ is a cost centre recharging services to affiliates; if ZATCA disputes the recharge margin, the dispute lands on income nominally taxed at 0% but whose eligibility is the question.

What are the qualifying criteria for an RHQ licence?

ZATCA’s rules name the mandatory set as business planning, budgeting, monitoring financial performance, preparing the MENA marketing strategy, and supporting merger and acquisition activity. The elective set includes human resources, training, accounting, auditing, and logistics and supply-chain management [S4].

Read against the licence count, these thresholds are the most useful figures on this page. Fifteen employees and three executives is the floor. Across 780 licences the mandated aggregate is roughly 11,700 jobs — arithmetic on the published rule, not a measured figure, and a rounding error against a Saudi labour force in the tens of millions. The programme was never an employment instrument. It was built to relocate decision-making authority, and its own minimum tells you how much the state considered sufficient. Saudisation obligations resume when the 10-year waiver expires; see Saudisation compliance and Saudi labour law.

How many RHQ licences has Saudi Arabia issued against the 480 target?

The verified series:

Resolving the target. Two numbers circulate. The Vision 2030 objective as stated in 2023 was 480 companies by 2030 [S18]; later coverage rounds it to 500. Both trace to the same policy — 480 is the figure in contemporaneous reporting, 500 a rounded restatement. Against either, the programme cleared its 2030 goal in 2024 and stood at roughly 1.6 times target by early 2026.

The quarterly run rate is the more revealing number. MISA issued just 34 licences in the second quarter of 2025 [S11], against a 2023 pace of roughly 180 a year [S19]. Licensing was front-loaded into the compliance deadline, as a procurement rule predicts; what follows a deadline-driven rush is a flatter curve.

Which companies have moved their regional HQ to Riyadh?

The ledger below includes only companies named in official programme material or tier-one reporting. MISA publishes no complete register, so this is a partial list assembled from disclosure, not a census.

Two names dropped. Unilever appears in secondary compilations as an RHQ holder, and Citi in aggregated related-article text; neither was confirmed by official material or a tier-one outlet, so both are excluded. This page will not assert what it could not source.

The consultancies are the clearest case of substance. PwC’s Riyadh RHQ occupies 22,400 square metres at Laysen Valley and the firm reports over 2,600 professionals in Saudi Arabia, 56% of them Saudi nationals, with Middle East chairman Riyadh Al-Najjar calling the building “an investment” in Vision 2030 [S13]. Bain’s April 2025 move to the King Abdullah Financial District was its third Riyadh location and more than doubled its footprint [S14]. Neither is a brass plate.

Are these real relocations or nameplate compliance?

The evidence is thin, and thin in a specific, describable way. Saudi Arabia publishes the licence count and not the substance data. There is no public RHQ register, no aggregate headcount series, no floor-space or payroll total, no operational-status dataset. Any confident claim about what share of 780 licences represents genuine relocation — in either direction — runs ahead of the record.

The evidence for substance

CBRE’s Q1 2026 review attributes Riyadh’s Grade A scarcity directly to “the physical residency of over 780 international firms under the RHQ programme,” alongside a 98% occupancy rate [S15]. Physical residency is a property consultancy’s judgement rather than a government statistic, but it is made by people who count leases. The PwC and Bain footprints are documented and large [S13][S14]. And ZATCA’s nine substance conditions are enforceable through the relief itself: an RHQ that fails them loses the 0% rate [S4].

The evidence for nameplate compliance

Semafor’s reporting of 4 October 2024 is the most direct account on the record. Firms were splitting the region — grouping Saudi Arabia, Bahrain and Oman as one “region” headquartered in Riyadh while keeping Dubai as head office for the rest — a structure that satisfies the rule without moving the business [S12]. What an actual move costs the people involved — rent, schooling and take-home pay in each city — is modelled in our side-by-side of what a package is worth in Riyadh and in Dubai. At least one major Wall Street bank was actively seeking loopholes, per two executives with direct knowledge, unnamed to avoid retribution. A Gulf-based headhunter recruiting for banks told Semafor that for the biggest brands “there is always a workaround.” Goldman Sachs took a licence in May 2024 and said nothing about implementation [S12].

The state appears to have expected this. Robert Mogielnicki of the Arab Gulf States Institute in Washington wrote on 5 December 2023, the day the tax package was announced, that implementation would “likely involve a certain degree of fuzziness… to enable greater policy flexibility” [S19]. The November 2025 Etimad mechanism is that flexibility formalised.

A widely quoted figure this page will not assert. Secondary coverage frequently states that of roughly 600 licences, about 350 RHQs are operational, some 90% in Riyadh, attributing the split to the Ministry of Investment. The Saudi Press Agency release it traces to blocked automated retrieval for this research. The figure is plausible, but graded reported, not documented — it should not be used as though MISA maintains a published operational register.

The defensible conclusion is narrower than either the official framing or the sceptical one. The programme has demonstrably relocated the professional-services industry’s regional leadership, because that industry’s revenue is Saudi state revenue and it had no alternative. Beyond that band, the minimum viable RHQ is a small thing to build, and the state has published nothing that would let an outsider tell a firm that built the minimum from one that moved its business.

How Dubai and Abu Dhabi compete: DIFC, ADGM and DMCC

The UAE did not respond by matching the mandate. It kept doing what it was already doing, and the numbers suggest that worked.

Those are not the numbers of hubs being hollowed out. DMCC, Dubai’s commodities free zone, remains the largest UAE free zone by membership, though a current verified member count could not be sourced. Riyadh took a function the UAE never really had — proximity to Saudi state procurement — while the UAE’s financial-centre and trading businesses kept compounding.

The real trade-off is now a tax question, and it cuts the other way from how it is usually told. UAE federal corporate tax is 9% above AED375,000, with 0% preserved for Qualifying Free Zone Persons on qualifying income. But the UAE enacted a 15% Domestic Minimum Top-up Tax under Cabinet Decision No. 142 of 2024, applying to financial years starting on or after 1 January 2025 for groups within Pillar Two scope — consolidated revenue of EUR750m or more [S22]. For a large group, the UAE free-zone 0% is already floored at 15%.

Saudi Arabia has not legislated an equivalent. PwC’s Worldwide Tax Summaries entry for the Kingdom, reviewed 29 July 2026, lists the RHQ Tax Rules, the 2024 zakat regulations and the new real estate transaction tax among significant developments, and records no domestic minimum top-up tax [S5]. Independent GCC tax surveys likewise place the Kingdom outside the DMTT group as of mid-2026.

The consequence is precise and largely unremarked: for a EUR750m-plus group, an RHQ’s 0% rate is not floored by Saudi law, but the top-up can still be collected elsewhere — by the parent jurisdiction under an income inclusion rule, or by another under an undertaxed profits rule. The headline benefit survives intact only below the Pillar Two threshold, or for as long as no other state reaches for it. See also Saudi vs UAE vs Qatar market entry, which covers hiring and employer-of-record routes rather than the headquarters instrument, and the Saudi Arabia vs UAE benchmark.

What the RHQ programme did to Riyadh’s office market

Riyadh’s office market is the clearest measurable consequence of the programme, and by the first quarter of 2026 it was still tightening. JLL’s KSA Office Market Dynamics for Q1 2026, published 7 May 2026, found prime and Grade A rents “maintaining upward momentum in Riyadh, supported by supply constraints and strong demand” [S17]. Figures from that research put Riyadh office vacancy at approximately 3.2% across all categories, with prime rents up 5.5%, Grade A up 2.1% and Grade B up 5.1% year on year. Some 179,400 square metres were delivered in the quarter, with roughly 1.2 million square metres more due by end-2026 [S16]. CBRE, on the same quarter, recorded 98% occupancy and tied it explicitly to RHQ residency [S15].

Two contrasts make that attribution credible rather than assumed. Jeddah moved the other way: Grade A vacancy of 6% and Grade A rents down 3.8% in the same quarter, so the pressure is Riyadh-specific — what a policy naming one city should produce. And Riyadh residential cooled while offices tightened: 8,600 transactions, down 54.4% year on year, apartment prices down 10.8% [S16]. An office market at 98% occupancy alongside a residential market down by half is not the signature of a mass inflow of households. It is corporate floor space being absorbed faster than corporate families arrive — the pattern a 15-employee minimum would generate.

The King Abdullah Financial District, which struggled for tenants for a decade, is now the default RHQ address [S14]. See investing in the Riyadh region and what Vision 2030 built.

Why This Matters for Vision 2030

The Saudi Arabia regional headquarters programme is the cleanest example in the Vision 2030 toolkit of using sovereign procurement as an industrial-policy lever, and the only one with a countable output. Foreign direct investment targets have proved difficult; the RHQ target was met six years early because it measured licences rather than capital. That is both the programme’s success and its analytical weakness — a KPI whose definition the state controls.

Its value is real but indirect. It moves regional decision-makers inside the Kingdom, shortening the distance between a giga-project procurement decision and the partner who can approve a bid; and it gives MISA an instrument that works independently of oil prices or PIF deployment. What it has not done is convert into the FDI numbers Vision 2030 targets — see FDI in Saudi Arabia, the foreign investment law and the Vision 2030 investment opportunities overview.

Risks, Contradictions and Open Questions

The substance data does not exist publicly. Until MISA publishes headcount or operational status by licence, no one — this page included — can state what share of 780 licences represents relocated business.

The exemption mechanism weakens the instrument it protects. A rule enforced by exception is a rule whose price has been discovered. The 25% test tells every non-RHQ bidder what compliance is worth in margin, and every holder the ceiling on what it can charge for Riyadh overhead [S9][S10].

Pillar Two is unresolved, and it is the largest variable in the package’s value. Published sources disagree on how far Saudi Arabia has progressed toward a qualified domestic minimum top-up tax: PwC’s July 2026 review records none [S5], while some tax commentary describes implementation as under way for fiscal 2026. Until ZATCA publishes a qualified DMTT, in-scope groups face top-up exposure abroad rather than a preserved 0% — and if it publishes one, the benefit is neutralised at home for exactly the largest companies the programme was built to attract.

The 30-year clock starts at licensing, not at operation. Firms that filed early in the 2023–24 rush are burning exemption years on offices that may not yet be at full function.

Enforcement of the substance tests is untested in public. No published case shows ZATCA withdrawing RHQ relief, or MISA revoking a licence for missing the 15-employee threshold. The tests exist; the record of their application does not. And the demand base may be contracting: if project awards tighten, the licence is worth less each year — while the exemption route makes it cheaper for the state to buy from non-holders.

What to Watch Next

• MISA’s quarterly Economic and Investment Monitor. The Q2 2025 edition reported 34 licences [S11]. The run rate, not the cumulative total, is the signal.
• Any ZATCA publication on a domestic minimum top-up tax. It determines whether the 30-year package is worth anything to a EUR750m-plus group.
• The first published enforcement action — a withdrawn licence or tax relief, converting the substance rules from text into precedent.
• Etimad exemption volumes. If the Local Content and Government Procurement Authority publishes how many it grants, that measures how binding the mandate remains.
• Riyadh Grade A absorption against the 1.2 million square metres due by end-2026 [S16] — the test of whether RHQ demand was structural or a deadline effect.
• Whether any licence holder publicly exits. None has. The first would be more informative than the next hundred arrivals.

Related Vision 2030 Context

• The Riyadh Mandate — why the mandate happened; this page documents how the rules work.
• The Riyadh Mandate Revisited — the second-order consequences for rents, talent and housing. This page is the programme reference; that one is the consequence analysis.
• Saudi vs UAE vs Qatar market entry — hiring and employer-of-record routes across three markets.
• Ministry of Investment (MISA) — the licensing authority.
• Saudi Arabia tax overview for investors — the standard regime the exemption departs from.
• Special economic zones — the parallel incentive regime, with its own 5% rate.
• Employer of record in Saudi Arabia — the lighter-weight hiring route an RHQ is not.
• Joint ventures and dispute resolution — structuring and enforcement context.

Sources

• [S1] Invest Saudi (Ministry of Investment and Royal Commission for Riyadh City), Regional Headquarters (RHQ) Programme, official programme page, accessed 31 July 2026. https://catalyzesaudi.sa/RHQ/
• [S2] Invest Saudi, RHQ Investor Manual, official programme document, February 2024. https://catalyzesaudi.sa/RHQ/wp-content/uploads/2024/08/Investor-Manual-English.pdf
• [S3] EY Global, Saudi Arabia Offers 30-Year Tax Holiday Under Regional Headquarters Program, tax alert, December 2023. https://www.ey.com/en_gl/technical/tax-alerts/saudi-arabia-offers-30-year-tax-holiday-under-regional-headquart
• [S4] King & Spalding, ZATCA Clarifies the Requirements for Granting a 30-Year Tax Relief to Multinational Corporations Under the Regional Headquarters Program, client alert, February 2024. https://www.kslaw.com/news-and-insights/zatca-clarifies-the-requirements-for-granting-a-30-year-tax-relief-to-multinational-corporations-under-the-regional-headquarters-program
• [S5] PwC, Worldwide Tax Summaries — Saudi Arabia: Significant Developments, tax reference, reviewed 29 July 2026. https://taxsummaries.pwc.com/saudi-arabia/corporate/significant-developments
• [S6] DLA Piper, Saudi Regional Headquarters Program: An Overview of Tax and Non-Tax Incentives, Gulf Tax Insights, February 2024. https://www.dlapiper.com/en/insights/publications/gulf-tax-insights/2024/gulf-tax-insights-february-2024/saudi-regional-headquarters-program-an-overview-of-tax-and-non-tax-incentives
• [S7] Mayer Brown, Updates on Saudi Arabia’s Regional Headquarters Program, client alert, 23 April 2024. https://www.mayerbrown.com/en/insights/publications/2024/04/updates-on-saudi-arabias-regional-headquarters-program
• [S8] AGBI, ‘No Loopholes for Companies’ to Be Found in Saudi HQ Rules, news, 3 January 2024. https://www.agbi.com/employment/2024/01/saudi-regional-hq-programme-rules-loopholes/
• [S9] Arab News, Saudi Arabia Allows Contracting Exceptions for Firms Without Regional HQ, news, 22 February 2026. https://www.arabnews.com/node/2633989/business-economy
• [S10] Middle East Briefing, Saudi Arabia Refines RHQ Procurement Rule: What’s New, analysis, 25 February 2026. https://www.middleeastbriefing.com/news/saudi-arabia-refines-rhq-procurement-rule/
• [S11] Arab News, Saudi Arabia Issues 34 Licenses for Regional HQs in Q2: Investment Ministry, news, 24 August 2025. https://www.arabnews.com/node/2612858/business-economy
• [S12] Semafor, Saudi HQ Rules Force Executives to Scramble for Loopholes, news, 4 October 2024. https://www.semafor.com/article/10/04/2024/saudi-hq-coup-forces-executives-to-scramble-for-loopholes
• [S13] Arab News, PwC Unveils Regional Headquarters in Riyadh’s Laysen Valley, news, 11 September 2025. https://www.arabnews.com/node/2614908/business-economy
• [S14] Arab News, Bain & Co. Chooses Riyadh for Regional HQ Amid Saudi Business Push, news, 17 April 2025. https://www.arabnews.com/node/2597436/business-economy
• [S15] CBRE, Saudi Arabia Real Estate Market Review Q1 2026, market report, 20 May 2026. https://www.cbre.com/insights/figures/saudi-arabia-real-estate-market-review-q1-2026
• [S16] Argaam, Saudi Property Market Shows Strength in Q1 2026: JLL, news, 29 May 2026. https://www.argaam.com/en/article/articledetail/id/1908894
• [S17] JLL, KSA Office Market Dynamics Q1 2026, market report, 7 May 2026. https://www.jll.com/en-sa/insights/market-dynamics/ksa-office
• [S18] Atlantic Council (Stefanie Hausheer Ali), Saudi Arabia Is Requiring Companies to Establish Headquarters in the Kingdom. That Strategy May Pay Off, analysis, 9 June 2023. https://www.atlanticcouncil.org/blogs/menasource/saudi-arabia-headquarters-economy/
• [S19] Arab Gulf States Institute in Washington (Robert Mogielnicki), Saudi Regional Headquarters Program Deadline Looms, analysis, 5 December 2023. https://agsi.org/analysis/saudi-regional-headquarters-program-deadline-looms/
• [S20] DIFC, Dubai International Financial Centre Announces Landmark Annual Results for 2025, press release, 5 February 2026. https://www.difc.com/whats-on/news/dubai-international-financial-centre-announces-landmark-annual-results-for-2025
• [S21] ADGM, ADGM Celebrates Decade of Operations With 36% Surge in AUM, 51% Increase in Workforce and Over 12,000 Licences in 2025, press release, 2026. https://www.adgm.com/media/announcements/adgm-celebrates-decade-of-operations-with-36-surge-in-aum-51-increase-in-workforce-and-over-12000-licences-in-2025
• [S22] EY Global, UAE Issues Domestic Minimum Top-Up Tax Legislation, tax alert, 2025. https://www.ey.com/en_gl/technical/tax-alerts/uae-issues-domestic-minimum-top-up-tax-legislation
• [S23] DGA Group, Saudi Arabia’s Regional Headquarters Program: Where Are We Now and What’s Next?, analysis, 23 May 2024. https://dgagroup.com/insight/analysis-saudi-arabias-regional-headquarters-program-where-are-we-now-and-whats-next/
• [S24] Saudi Press Agency, 30-Year Tax Relief Added to Incentives for the Saudi Program for Attracting Regional Headquarters of Multinational Companies, government release, 5 December 2023. https://www.spa.gov.sa/en/N2009098

Note on sources: spa.gov.sa and several consultancy report pages blocked automated retrieval for this research. Where a primary release could not be read directly, the figure is carried on the named outlet or professional-firm alert that reported it, and that source is cited in place of the primary. This is stated in the text wherever it affects a figure.