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Iran
HANGE NOTES BETWEEN
THE ISLAMIC REPUBLIC OF PAKISTAN AND THE
IMPERIAL GOVERNMENT OF IRAN CONCERNING THE RECIPROCAL EXEMPTION OF AIRLINES FROM PAYMENT
OF INCOME-TAX.
[Notification No. S.R.O. 1452(1)/78, dated the 16th December, 1978]
I
Imperial Embassy of Iran,
Islamabad.
No. 8543
15th February, 1978.
"The Imperial Embassy of Iran presents its compliments to the Ministry of Foreign
Affairs, Government of the Islamic Republic of Pakistan and has the honour to State that:
WHEREAS in accordance with the Direct Taxation Law of 28 Esfand 1345 (19th March, 1967),
foreign airlines may be exempted from payment of income-tax on a reciprocal basis.
WHEREAS no income-tax has been collected from Iran Air in Pakistan, and the Iranian
Government has to this date refrained from collecting income-tax from Pakistan
International Airlines Corporation, and
WHEREAS the provisions of reciprocity prescribed is the Iranian Direct Tax Law, has thus
in fact been established;
It is, therefore, proposed that as long as reciprocity is observed by the Government of
Pakistan in this respect, Pakistani airlines will be, as before, exempted in Iran from the
payment of income-tax derived from the transportation of goods and passengers.
It is furthermore, proposed that should the above be acceptable to the Government of
Pakistan, this note and the Ministry's note in reply confirming the application and
observance of reciprocity by the Government of Pakistan, be considered as a temporary
agreement between the two Governments in respect of exemption from payment of income-tax
by their airlines.
The Embassy avails itself of this opportunity to renew to the Ministry the assurance of
its highest consideration."
The Ministry of Foreign Affairs,
Government of the Islamic Republic of Pakistan,
Islamabad.
II
No. Ira (I)-VI/2(2)78.
March 8, 1978.
"The Ministry of Foreign Affairs presents its compliments to the Imperial Embassy of
Iran in Islamabad and has the honour to acknowledge receipts of the Embassy's Note No.
8543, dated February 15, 1978, which reads as follows:
The Imperial Embassy of Iran presents its compliments to the Ministry of Foreign Affairs,
Government of the Islamic Republic of Pakistan and has the honour to state that:
WHEREAS in accordance with the Direct Taxation law of 28 Esfand 1345 (19th March, 1967),
foreign airlines may be exempted from payment of income-tax on a reciprocal basis, and
WHEREAS no income-tax has been collected from Iran Air in Pakistan, and the Iranian
Government has to this date refrained from collecting income-tax from Pakistan
International Airlines Corporation, and
WHEREAS the provisions of reciprocity prescribed in the Iranian Direct Tax Law, has thus
in fact been established.
It is, therefore, proposed that as long as reciprocity is observed by the Government of
Pakistan in this respect, Pakistan airlines will be, as before, exempted in Iran from the
payment of income-tax derived from the transportation of goods and passengers.
It is furthermore proposed that should the above be acceptable to the Government of
Pakistan, this note and the Ministry's note in reply confirming the application and
observance of reciprocity by the Government of Pakistan, be considered as a temporary
agreement between the two Governments in respect of exemption from payment of income-tax
by their airlines.
The Embassy avails itself of this opportunity to renew to the Ministry the assurances of
its highest consideration."
The Ministry has further the honour to inform the Embassy that the Foregoing is acceptable
to the Government of Islamic Republic of Pakistan and that the Government of the Islamic
Republic of Pakistan will take appropriate action under Notification No. 735(I)/77 dated
10th August, 1977 (Copy enclosed) under section 660 of the Income-tax Act with effect from
1958-59.
The Ministry avails itself of this opportunity to renew to the Embassy the assurance of
its highest consideration.
The Imperial Embassy of Iran,
Islamabad.
SD/-
AFTAB AHMAD,
[C. No. 2(7) TL/61.] Additional Secretary.
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