| |
|
 |
| For business information, annual reports, laws, ordinances, regulations and articles. |
|
|
|
(Netherland) Holland
EXCHANGE NOTES BETWEEN THE ISLAMIC REPUBLIC OF PAKISTAN AND THE ROYAL NETHERLANDS
GOVERNMENT CONCERNING THE RECIPROCAL EXEMPTION OF SHIPPING AND AIR TRANSPORT FROM PAYMENT
OF INCOME-TAX.
[Notification S.R.O. 643(1)/79, dated the 5th July, 1979]
Embassy of Pakistan
[No. EC- 1/5/79 CR.]
The Hague.
The Embassy of Pakistan presents compliments to the Ministry of Foreign Affairs of the
Royal Netherlands Government and, with reference to section 19 of the Netherlands
Corporation Tax Act, 1969, which, subject to reciprocity, grants tax exemption to foreign
air and shipping enterprises operating in international traffic, has the honour to inform
as follows:
Under SRO 735 (I)/77, dated August 10, 1977, issued under section 60 of the Income Tax
Act, 1922, income of a foreign enterprise derived from operation of ships and aircraft in
international traffic may be exempted from payment of income-tax on a reciprocal basis.
A copy of the relevant legal provisions is enclosed.
The Government of the Islamic Republic of Pakistan, therefore, confirms the principle of
reciprocity by stating that, subject to grant by the Royal Netherlands Government of
exemption from income-tax on income of air and shipping enterprises of Pakistan from
international traffic, the Dutch enterprises deriving income from operation of ships and
aircraft from international traffic shall be exempt from income-tax in Pakistan. The
proposed tax exemption would be applicable to the income of the air and shipping
enterprises of the respective countries as derived from the 1st day of January, 1970.
The Embassy of Pakistan, therefore, requests the Ministry of Foreign Affairs of the Royal
Netherlands Government to confirm that the principle of reciprocity in fiscal matters will
be applied to the air and shipping enterprises of Pakistan.
The Embassy of Pakistan avails itself of this opportunity to renew to the Ministry of
Foreign Affairs of the Royal Netherlands Government the assurance of its Highest
consideration.
| Ministry of Foreign Affairs of the Royal Netherlands Government (Treaties Department) The Hague. | The Hague____________ |
TREATIES DEPARTMENT
[DVE/W-91373.]
II
The Ministry of Foreign Affairs presents its compliments to the
Embassy of Pakistan and has the honour to confirm receipt of the Embassy's Note No.
EC-1/5/79 CR which reads as follows:
"The Embassy of the Islamic Republic of Pakistan presents its compliments to the
Ministry of Foreign Affairs of the Royal Netherlands' Government and, with reference to
section 19 of the Netherlands Corporation Tax Act, 1969, which subject to reciprocity,
grants tax exemption to foreign air and shipping enterprises operating in international
traffic, has the honour to inform as follows:
Under SRO 735(I)/77, dated August 10, 1977, issued under section 60 of Income- tax Act,
1922, income of foreign enterprises derived from operation of ships and aircraft in
international traffic may be exempted from payment of income-tax on a reciprocal basis.
A copy of the relevant legal provisions is enclosed. The Government of Islamic Republic of
Pakistan, therefore, confirms the principle of reciprocity by stating that, subject to
grant by the Royal Netherlands Government of exemption from income-tax on income of air
and shipping enterprises of Pakistan from .international traffic, the Dutch enterprises
deriving income from operation of ships and aircraft from international traffic shall be
exempted from income-tax in Pakistan.
The proposed tax exemption would be applicable to the income of the air and shipping
enterprises of the perspective countries as derived from the 1st day of January, 1970. The
Embassy of the Islamic Republic of Pakistan, therefore, requests the Ministry of Foreign
Affairs of the Royal Netherlands Government to confirm that the principle of reciprocity
in fiscal matters will be applied to the air and shipping enterprises of Pakistan."
The Ministry has the honour to confirm that, according to the Netherlands law and subject
to reciprocity, foreign companies are not taxed in the Netherlands on foreign income or
other profits from the cooperation of ships or aircraft in international traffic.
This rule is embodied in the Corporation Tax Act of 1969 the relevant section (section 19)
of which reads as follows:
"If the country where the enterprise is established takes a corresponding position,
the following shall not be considered as carrying on an enterprise with the Netherlands by
a foreign country.
a. shipping and air transport of persons and goods between places within and places
outside the Netherlands, or between places outside the Netherlands, unless the management
of the enterprise is situated in the Netherlands;
In view of the content of the Embassy's Note and the section of the Dutch Legislation
reproduced above, the Royal Netherlands Government confirms that for income as derived
from the 1st day of January, 1970 the principle of reciprocity in fiscal matters will be
applied to the air and shipping enterprises of Pakistan."
The Hague, 20 June, 1979.
The Embassy of
Pakistan at |
ABDUL WAHEED, |
(SEAL) |
|
|
|
|
|
|
| Home | About Us | Contact | Information Resources |