The foreign partner who owns less than 50% in a mixed Saudi company does not fall within the definition of Related Persons as stipulated in article 64 of the Income Tax Law, so such services are not subject to  a 15% Withholding Tax, but a 5% Withholding Tax, because the definition of ownership is only effectuated when the percentage of ownership is 50% or more as stipulated in paragraph (c) of Article (64) of the Law.