The withholding tax rates in the treaty are as follows.
Capital gains on shares could be taxed in the State where the company is located unless the beneficial owner has at least 10% of the shares in the company. Capital gains on shares and dividends in the hands of individuals can still be taxed in The Netherlands after emigration for a period of 10 years.
In the treaty it is also mentioned that companies that are not subject to tax in Saudi Arabia for a limited period of time not exceeding ten years from tax on income in Saudi Arabia under the provisions of encouragement of its investment still meet the subject to tax test for Dutch participation exemption purposes.