Foreign investment in retail and wholesale activities was liberalised in 2016 to allow 100% foreign ownership with conditions as per the following: i) minimum capital of SR 30 million [approx. USD 8 million] is required for being entitled to 100% foreign ownership; ii) minimum capital of SR20 million [approx. USD 5.3 million] is required for being entitled to invest in partnership with Saudi local partner and hold up to 75% foreign ownership. Further conditions on employment of Saudi individuals and local procurement also apply.
"Summary:
The controls included: allowing foreigners to invest in the wholesale and retail trade sector with a percentage of ownership (100%) limited to companies who have a presence in (3) markets according to the controls and conditions stated in the decision, companies excluded from some provisions, exemption from some controls and conditions, reviewing the terms and conditions and results Apply them and give opinions and suggestions" (Cabinet Resolution No. (377), dated 8/9/1437H [14/6/2016])
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"03.07 Commercial License
Considering the importance of commercial activities in the Kingdom of Saudi Arabia and the pursuit the Kingdom to facilitate the entry of foreign entities to perform an activity in the wholesale trade and retail trade in the Saudi market, according to specific guidelines and conditions, it has introduced a number of options for ambitious foreign, namely:
1. Commercial license with Saudi shareholder under the service number (03.07.01) of this manual.
2. 100% foreign commercial license under the service number (03.07.02) of this manual.
03.07.01 Commercial license with Saudi shareholder
- Service Description: 
This Service is provided to foreign entities that are interested in the activity of wholesale and retail trade in the Kingdom of Saudi Arabia with a Saudi shareholder. [...]
- Service Rules and Restrictions
1. The existence of a Saudi shareholder in the investment license with a share of not less than 25% of the company.
[...]
03.07.02 100% foreign commercial license
- Service Description
This Service is provided to 100% foreign entities that are interested in the activity of wholesale and retail trade and e-commerce in the Kingdom of Saudi Arabia. [...]
 Service Rules and Restrictions
1- This service is limited to the foreign companies that have a presence at least in (3) regional or international markets. [...]
3- The company shall comply to achieve following standards during the first five years:
 The company shall comply to achieve the localization rates as determined by the Ministry of Labor and Social Development. The company shall develop and implement
a plan to locate them in senior management posts in the first five years and to ensure their continuation.
 The company is complying with train (30%) of Saudi employees annually.[...]
4- The company shall comply to achieve one of the following options:
 Option 1: the company shall comply with investing an amount of no less than 300 million Saudi Riyals (including 30 million Saudi Riyals as the cash capital of the company) over five years starting from the date of obtaining the investment license.
 Option 2: the company shall comply with investing an amount of no less than 200 million Saudi Riyals (including 30 million Saudi Riyals as the cash capital of the company) over five years starting from the date of obtaining the investment license, in addition to achieving one or more of the following requirements during the first five years:
Manufacturing - The minimum requirement:  % 30 or more of the company's products distributed locally shall be manufactured in the Kingdom of Saudi Arabia
Research and development programs -The minimum requirement: % 5 or more of total sales shall be allocated to the establishment of a research and development programs in the Kingdom
Logistics and distribution - The minimum requirement: The establishment of a unified center to provide those services, and provide after-sales services [...]" (Ministry of Investment, Services Manual [8th edition], Jan 2020)
Cabinet Resolution No. (377), dated 8/9/1437H [14/6/2016]
Ministry of Investment, Services Manual [8th edition], Jan 2020
[<a href="http://ncar.gov.sa/Documents/Details?Id=AeG3gtq%2BOuLBp0om2yDe%2FQ%3D%3D">Resolution</a>],[<a href="https://www.misa.gov.sa/media/1128/moi-service-manual-8th-edition-en-v4.pdf">Manual</a>]