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(Hellenic Republic) Greece

MINISTRY OF FINANCE AND ECONOMIC COORDINATION

(Finance Division)
Islamabad, the 19th February, 1980

(Income Tax)

S.R.O. 212(1)/80. - WHEREAS the annexed Agreement between the Islamic Republic of Pakistan and the Hellenic Republic for the avoidance of double taxation of income derived from operation of ships and aircraft has been made;

Now, THEREFORE, in exercise of the powers conferred by section 163 of the Income Tax Ordinance, 1979 (XXXI of 1979), the Federal Government is pleased to direct that all the provisions of the said Agreement shall be given effect to in Pakistan.

Annex

AGREEMENT
BETWEEN THE ISLAMIC REPUBLIC OF PAKISTAN AND THE HELLENIC
REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION OF INCOME DERIVED FROM THE OPERATION OF SHIPS AND AIRCRAFT.

The Government of the Islamic Republic of Pakistan and the Government of the Hellenic Republic in their desire to conclude fin agreement for the avoidance ,of double taxation of income derived from the operation of ships and aircraft in international traffic, have agreed as follows:

ARTICLE 1

1. The existing taxes to which this Agreement shall apply are in particular:

(a) In the case of the Islamic Republic of Pakistan:

the income-tax, the super-tax and the surcharge.

(b) In the case of the Hellenic Republic:
the income-tax on legal entities and natural persons, the contribution for Agricultural Insurance and all other taxes on income, additional taxes or other contributions, which are chargeable in the territory of the Hellenic Republic.

2. The Agreement shall also apply to all identical or substantially similar taxes which are imposed in addition to or in place of, the existing taxes.

ARTICLE 2

For the purpose of this Agreement:

1. The term "operation of ships and aircraft" means the professional activity of transportation by sea and air of persons, animals, goods and mail including the sale of pessage tickets and similar documents for such transportation and other activity directly incidental thereto.

2. The term "international traffic" means any transport by a ship or aircraft except when the ship or aircraft is operated solely between places situated in the territory of a Contracting State.

3. The term "a Contracting State" means Pakistan or Greece, as the context requires.

ARTICLE 3

Income derived from the operation of a ship in international traffic shall be taxable only in the Contracting State in which the ship is registered or documented.

ARTICLE 4

1. Income of an air transport enterprise of a Contracting State derived from the operation of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

2. The term "air-transport enterprise" means an enterprise of a Contracting State operated by the State, or a person, natural or legal, who is resident under the laws of that State.

ARTICLE 5

1. This Agreement shall be ratified in accordance with the legal requirements of the Contracting States and shall come into force on the date of the exchange of the instruments of ratification.

2. This Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year. In such an event the Agreement shall cease to effect on the first day of January following the expiration of the six months period.

IN WITNESS THEREOF the undersigned, duly authorized thereto, have signed this Agreement and have affixed thereto their seals.

DONE AT ................. on the ............ day .......... of ........... 19 ....... in the English and Greek languages. both texts being equally authentic.

Date .............

Dear Mr. Chairman,
With reference to the Agreement for the Avoidance of Double Taxation of Income derived from the operation of ships and aircraft between our two countries signed this same day at .............. , I have the honour to state that the two Delegations agreed during the discussions that the provisions of Article 4, of the said Agreement shall have effect in respect of income derived as from January 1, 1971.

In case the foregoing is acceptable to your Government, I propose that this letter together with your reply indicating such acceptance constitute an agreement between our two countries on this matter."

Date.............................

DEAR MR. CHAIRMAN,

I have the honour to acknowledge receipt of your letter of................reading as follows:

"With reference to the Agreement for the Avoidance of Double Taxation of income derived from the operation of ships and aircraft between our two countries, signed this same day at..............I have the honour to state that the two Delegations agreed during the discussions that the provisions of Article IV of the said Agreement shall have effect in respect of income derived as from January 1, 1971.

In case the foregoing is acceptable to your Government, I propose that this letter together with your reply indicating such acceptance constitute an agreement between our two countries on this matter."

I have the honour to confirm that the contents thereof are acceptable to my Government and that, therefore, your above letter together with this letter constitute an Agreement between our two countries on this matter.

ABDUL WAHEED,
Joint Secretary.

[C. No. 2(16) TL/69.]

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