Double Taxation Agreement - Volume II

For business information, annual reports, laws, ordinances, regulations and articles.

AGREEMENT BETWEEN
THE ISLAMIC REPUBLIC OF PAKISTAN AND THE ISLAMIC REPUBLIC OF IRAN FOR THE AVOIDANCE OF DOUBLE TAXATION

S.R.O. 785(I)/90, dated 22-07-1990. - WHEREAS the annexed agreement for the avoidance of double taxation on income of enterprises derived from shipping activities in international traffic has been made between the Government of the Islamic Republic of Pakistan and the Government of the Islamic Republic of Iran

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 have effect in Pakistan from the first day of January, 1989.

AGREEMENT BETWEEN THE ISLAMIC REPUBLIC OF PAKISTAN AND THE ISLAMIC REPUBLIC OF IRAN FOR RECIPROCAL TAX EXEMPTION ON INCOME OF ENTERPRISES DERIVED FROM SHIPPING ACTIVITIES IN INTERNATIONAL TRAFFIC

The Government of the Islamic Republic of Pakistan and the Government of the Islamic Republic of Iran desiring to conclude an Agreement for the reciprocal tax exemption on income of enterprises derived from shipping activities in international traffic, have agreed as follows :-

ARTICLE 1
TAXES COVERED

1. The existing taxes to which this agreement applies 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 Islamic Republic of Iran, the income-tax.

2. This 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
DEFINITIONS

1. In this Agreement, unless the context otherwise requires -
(a) the terms "a Contracting State" and "the other Contracting State" mean Pakistan or Iran, as the context requires;

(b) the term "enterprise of a Contracting State" means an enterprise, the control and management of whose affairs is situated wholly in the territory of that Contracting State;

(c) the term "international traffic" means any transport by a ship except when the ship is operated solely between places situated in the territory of a Contracting State;

(d) the term "shipping activities" means the professional activities of transportation by sea of passengers, goods, livestock and mail by a ship owned, or by any title managed by an enterprise of a Contracting State, including the sale of passage tickets and similar documents for such transportation.

2. As regards the application of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which this Agreement applies.

ARTICLE 3
RECIPROCAL TAX EXEMPTION

Enterprises of a Contracting State shall be exempted from payment of tax in the other Contracting State on income derived from shipping activities in international traffic and all tile provisions of Article 2 of the Agreement shall apply accordingly.

ARTICLE 4
MUTUAL CONSULTATION AND EXCHANGE OF INFORMATION

The competent authorities of the Contracting States shall endeavour to resolve by mutual consent, any difficulties or doubts arising from the interpretation or application of the Agreement. The Contracting States may also exchange the necessary information regarding their respective taxation systems, laws and regulations.

ARTICLE 5
ENTRY INTO FORCE

This Agreement shall enter into force on the later of the dates on which the respective Governments have notified each other in writing that the formalities constitutionally required in their respective States have been complied with, and its provisions shall have effect in both States starting Day 11, 1367 Solar Hijri (the first day of January, 1989).

ARTICLE 6
TERMINATION

This Agreement shall continue in effect indefinitely but either Contracting State may give six months prior notice of termination to the other Contracting State and in such an event this Agreement shall cease to be effective from the first day of January of the calendar year following the year in which such notice is given.

DONE at Islamabad, on this day 22nd of Ordibehesh, 1969, Solar Hijri corresponding to May 12, 1990 in duplicate in the English and Farsi languages, both texts being equally authentic.

For the Government of the Islamic Republic of Pakistan.	For the Government of the Islamic Republic of Iran.
Sd/- (EHSANUL HAQ PIRACHA), Minister of State for Finance and Economic Affairs.	Sd/- (Dr. MOHSEN NOOR BAKHSH), Minister of Economic Affairs and Finance.

Home | About Us | Contact | Information Resources