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(Ceylon) Sri Lanka
NOTIFICATIONS
AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION
[PAKISTAN & CEYLON]
MINISTRY OF FINANCE
S.R.O. 39(R)/69, dated 23rd January, 1970. - Whereas the
annexed Convention between Government of Pakistan and the Government of Ceylon for the
avoidance of double taxation and the Prevention of Fiscal Evasion with respect to Taxes on
income and property has been made.
NOW, THEREFORE, in exercise of the powers conferred by section 49AA of the Income Tax Act,
1922 (XI of 1922), the Central Government is pleased to direct that all the provisions of
the said Convention shall be given effect to in Pakistan.
Annexure
CONVENTION BETWEEN THE GOVERNMENT OF PAKISTAN AND THE
GOVERNMENT OF CEYLON FOR THE AVOIDANCE OF DOUBLE
TAXATION AND THE PREVENTION OF FISCAL EVASION WITH
RESPECT TO TAXES ON INCOME AND PROPERTY.
The Government of Pakistan and the Government of Ceylon.
Desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention
of Fiscal Evasion with respect to Taxes on income and property.
Have agreed as follows:
ARTICLE I
(1) The taxes which are the subject of the present Convention
are:
(a) in Pakistan:
(i) the income-tax and super-tax, and
(ii) the wealth-tax
(b) in Ceylon:
(hereinafter referred to as "Pakistan tax").
(i) the income-tax, and
(ii) the wealth-tax (hereinafter referred to as "Ceylon tax").
(2) The present Convention shall also apply to any other taxes on a substantially similar
character imposed by either Contracting Government subsequently to the date of signature
of the present Convention or by the Government of any territory to which the present
Convention is extended under Article XXIII.
ARTICLE II
(1) In the present Convention, unless the context otherwise
requires:
(a) The term "Pakistan" means the Provinces of Pakistan and the Federal Capital;
(b) The terms "one of the territories" and "the other territory" mean
Pakistan or Ceylon, as the context requires;
(c) The term "tax" means Pakistan tax or Ceylon tax, as the context requires;
(d) The term "person" includes any body of persons, corporate or not corporate;
(e) The term "company" means any body corporate and includes any entity which is
treated as a body corporate for tax purposes under the laws of the respective territories;
(f) The terms "resident of Pakistan" and "resident of Ceylon" mean
respectively any person who is resident in Pakistan for the purposes of Pakistan tax and
not resident in Ceylon for the purposes of Ceylon tax, and any person who is resident in
Ceylon for the purposes of Ceylon tax and not resident in Pakistan for the purposes of
Pakistan tax;
A company shall be regarded as resident in Pakistan if its business is managed and
controlled in Pakistan or if it is incorporated under the laws of Pakistan and its
business is not managed and controlled in Ceylon;
A company shall be regarded as resident in Ceylon if its business is managed and
controlled in Ceylon or if it is incorporated under the laws of Ceylon and its business is
not managed and controlled in Pakistan;
(g) The term "Pakistan enterprise" and "Ceylon enterprise" mean
respectively an industrial or commercial enterprise or undertaking carried on in Pakistan
by a resident of Pakistan and an industrial or commercial enterprise or undertaking
carried on in Ceylon by a resident of Ceylon; and the terms "enterprise of one of the
territories" and "enterprise of the other territory" mean a Pakistan
enterprise or a Ceylon enterprise, as the context requires;
(h) The term "industrial or commercial profits" includes profits from business,
such as mining, banking, insurance, fishing, but does not include income from the
operation of ships or aircraft, or income in the form of dividends, interest, rent, or
royalties (including rent or royalties in respect of motion picture films or films used in
connection with television) or a fee or other remuneration derived from the management,
control or supervision of the trade, business, or other activities of an enterprise or
concern, or remuneration for labour or personal (including professional) services;
(i) The term "permanent establishment" when used with respect to an enterprise
of one of the territories means a branch, management, factory, or other fixed place of
business, a mine, quarry or any other place of natural resources, subject to exploitation.
In this connection:
(I) A person acting in one of the territories for or on behalf of an enterprise of the
other territory shall be deemed to be a permanent establishment in the first-mentioned
territory, if-
(aa) he has and habitually exercises in the first-mentioned territory a general authority
to negotiate and enter into contracts for or on behalf of the enterprise, or
(bb) he habitually maintains in the first-mentioned territory a stock of goods or
merchandise belonging to the enterprise from which that person regularly delivers goods or
merchandise for or on behalf of the enterprise, or
(cc) he habitually secures orders or is habitually instrumental in effecting sales in the
first-mentioned territory, wholly or almost wholly, for the enterprise itself, or for the
enterprise and other enterprises which are controlled by it or have a controlling interest
in it;
(ii) A broker of a genuinely independent status, who merely acts as an intermediary
between an enterprise of one of the territories and a prospective customer in the other
territory, shall not be deemed to be a permanent establishment in that other territory
where such activities do not involve securing of orders or effecting sales within the
meaning of clause (i) above; and
(iii) The fact that a company which is a resident of one of the territories has a
subsidiary company which is a resident of the other territory or which carries on a trade
or business in that other territory (whether through a permanent establishment or
otherwise) shall not of itself, constitute that subsidiary company a permanent
establishment of its parent company, and
(j) The term "component authorities" means, in the case of Pakistan, the Central
Board of Revenue or their authorised representative, and, in the case of Ceylon, the
Commissioner of Inland Revenue; and, in the case of any territory to which the present
Convention is extended under Article XXIII, the competent authority for the administration
of such territory of the taxes to which the present Convention applies.
(2) In the application of the provisions of the present Convention in one of the
territories any term not otherwise defined in the present Convention shall, unless the
context otherwise requires, have the meaning which it has under the laws in force in that
territory relating to the taxes which are the subject of the present Convention.
ARTICLE III
(1) The industrial or commercial profits of an enterprise of one
of the territories shall not be subjected to tax in the other territory unless the
enterprise carries on a trade or business in the other territory through a permanent
establishment situated therein. If it carries on a trade or business in that other
territory through a permanent establishment situated therein, tax may be imposed upon the
entire income of such enterprise from sources within that territory.
(2) Where an enterprise of one of the territories carries on a trade or business in the
other territory through a permanent establishment situated therein, there shall be
attributed to that permanent establishment the industrial or commercial profits which it
might be expected to derive in that other territory if it were an independent enterprise
engaged in the same or similar activities under the same or similar conditions and dealing
at arm's length with the enterprise of which it is a permanent establishment.
Provided that nothing in this paragraph shall affect the computation of the profits
derived by a Pakistan enterprise from the production of tea or other agricultural product
in Ceylon in accordance with the provisions of the law of Ceylon at the date of signature
of the present Convention.
ARTICLE IV
Where -
(a) the person carrying on an enterprise of One of the territories participates directly
or indirectly in the management, control or capital of an enterprise of the other
territory, or
(b) the same person participates directly or indirectly in the management, control or
capital of an enterprise of one of the territories and an enterprise of the other
territory,
and in either case, conditions are made or imposed between the two enterprises, in their
commercial or financial relations, which differ from those which would be made between
independent enterprises, then any profits which would but for those conditions have
accrued to one of the enterprises but by reason of those conditions have not so accrued
may be included in the profits of that enterprise and taxed accordingly.
ARTICLE V
(1) Profits derived by an enterprise of one of the territories
from the operation, in the other territory, of aircraft owned or chartered by that
enterprise may be subjected to tax in that other territory:
Provided that where such aircraft is not operated wholly or mainly between places within
such other territory, the amount of the tax so chargeable shall be reduced by a sum equal
to fifty per cent of the said amount.
(2) The provisions of paragraph (1) shall likewise apply in respect of profits derived
from participation in pools by enterprises engaged in air transport.
ARTICLE VI
(1) The rate of Pakistan super-tax on dividends paid to a company
being a resident of Ceylon and not having a permanent establishment in Pakistan by a
company being a resident of Pakistan and engaged in an industrial undertaking in Pakistan
shall be reduced by 6 per cent if the first-mentioned company owns more than one-third of
the voting shares of the latter company.
(2) The provisions of section 23A of the Pakistan Income-tax Act (relating to the
distribution of company profits) shall not apply to the income of a company being a
resident of Pakistan more than one-third voting shares of which are owned by a company
being a resident of Ceylon, if the first-mentioned company is engaged in an industrial
undertaking and its profits are retained for purposes of its industrial development and
expansion in Pakistan.
(3) Dividends paid by a company which is resident of Ceylon to a company which is resident
of Pakistan shall be exempt from Ceylon tax:
Provided that nothing contained in this paragraph shall apply to -
(a) the Ceylon tax payable by the first-mentioned company in respect of the profits out of
which the dividends are paid; and
(b) the additional tax, if any, referred to in sub-section (4) of section 26 of the Ceylon
Inland Revenue Act (No. 4 of 1963) (hereinafter referred to as the said additional tax)
payable by the first-mentioned company being a company whose shares are not deemed to be
movable property situated in Ceylon for the purposes of the law relating to the levy of
Estate duty in Ceylon; but the rate of the said additional tax shall not, in the case of
companies resident in Pakistan, exceed 6 per cent.
(4) Nothing contained in paragraphs (1), (2.) and (3) shall apply where a resident of one
of the territories has a permanent establishment in the other territory; in such event,
the provisions of Article III of the present Convention shall be applicable.
(5) Where a company which is a resident of one of the territories derives profits or
income from sources within the other territory, there shall not be imposed in that other
territory form of taxation on dividends paid by the company to a person not resident in
that other territory, unless such dividend is attributable to a permanent establishment
maintained in that other territory by a person not resident in that other territory, or
any tax in the nature of an undistributed profits tax on undistributed profits of the
company whether or not those dividends represent, in whole or in part, profits or income
so derived:
Provided that nothing contained in this paragraph shall affect the provisions of the
Pakistan law providing for the allowance of rebate of super-tax at a higher rate to
companies which make such arrangements, as may be prescribed in this behalf, for the
declaration and payment of dividends and the deduction of super-tax from dividends paid by
them than that allowed to other companies.
(6) In paragraphs (1) and (2) of this Article, the term "industrial undertaking"
means an undertaking falling under any of the clauses mentioned below, if it is set up, or
commenced after the present Convention comes into force or if the shares of the company
engaged therein are acquired by an enterprise of the other territory after that date:-
(a) The manufacture of goods or materials or the subjection of goods or materials to any
process which results in substantially changing their original condition;
(b) Ship-building;
(c) Electricity, hydraulic power, gas or water supply;
(d) Mining including the working of an oil-well or the source of any mineral deposit; and
(e) Any other undertaking, which may be declared by the competent authorities to be an
industrial undertaking for the purposes of this Article
ARTICLE VII
(1) The State Bank of Pakistan shall be exempt from Ceylon tax
with respect to interest from sources within Ceylon.
(2) The Central Bank of Ceylon shall be exempt from Pakistan tax with respect to interest
from sources within Pakistan.
(3) The Government of one of the territories shall be exempt from tax in the other
territory with respect to interest or loans or dividends received by that Government from
sources within the other territory.
(4) Any financial institution owned by the Government of one of the territories shall be
exempt from tax in the other territory with respect to interest on loans or dividends
received by that institution from sources within the other territory.
(5) The term "interest" as used in this Article means interest on bonds,
securities, notes, debentures or any other form of indebtedness (including mortgages or
bond secured by real property).
ARTICLE VIII
(1) Any royalty payable as consideration for the use of or for
the privilege of using any copyright, artistic or scientific work derived from sources
within one of the territories by a resident of the other territory shall be exempt from
tax in the first-mentioned territory.
(2) Any royalty [other than royalty to which paragraph (1) applies] derived from sources
within one of the territories by a resident of the other territory may be subjected to tax
in that first-mentioned territory but the amount of the tax so chargeable shall be reduced
by a sum equal to fifty per cent of the said amount.
(3) The provisions of paragraphs (1) and (2) of this Article shall not apply where the
person, being a resident of one of the territories and deriving income from royalty from
the other territory, is engaged in trade or business in that other territory through a
permanent establishment situated therein.
(4) Where any royalty exceeds a fair and reasonable consideration in respect of the rights
for which it is paid, the exemption or reduction provided by this Article shall apply only
to so much of the royalty as represents such fair and reasonable consideration.
(5) The term "royalty" as used in this Article means any royalty or other amount
paid as consideration for the use of or for the privilege of using any copy-right artistic
or scientific work, patent, design, secret process or formula, trade mark or other like
property or rights; but does not include any rent or royalty in respect of motion picture
films or films for use in connection with television, or any royalty or other amount paid
in respect of the operation of any mine or quarry or any other extraction of natural
resources.
ARTICLE IX
(1) Income from immovable property may be subjected to tax in the
territory in which the property is situated.
(2) Interest on debts secured by mortgages on real estate and royalties or other amounts
paid in respect of the operation of a mine, quarry or other place of extraction or
exploitation of natural resources shall, for the purposes of this Article, be regarded as
income derived from immovable property.
ARTICLE X
(1) Remuneration, including pensions and annuities, paid by or on
behalf of the Government of one of the territories to any individual for services rendered
to that Government in the discharge of Government functions shall be 'exempt from tax in
the other territory, if the individual is not ordinarily resident in that other territory,
or, where the remuneration is not a pension or annuity, is ordinarily resident in that
other territory solely for the purpose of rendering those services.
(2) The provisions of paragraph (1) of this Article shall not apply to payments in respect
of services rendered in connection with any trade or business carried on by the Government
of either of the territories for purposes of profit.
(3) The term "Government" as used in this Article includes the Government of a
Province or a State in Pakistan and a local authority in either territory.
ARTICLE Xl
(1) An individual who is a resident of one of the territories
shall be exempt from tax on profits or remuneration in respect of personal (including
professional) services rendered by him in the other territory in any year, if-
(a) he is temporary present in the other territory for a period or periods not exceeding
in the aggregate 183 days during that year.
(b) the services are performed for or on behalf of a resident of the first-mentioned
territory, and
(c) the profits or remuneration are borne by a resident of the first-mentioned territory
and are subject to tax in that territory.
(2) The provisions of paragraph (1) of this Article shall not apply to the profits or
remuneration of public entertainers, such as stage, motion picture, radio or television
artists, musicians and athletes.
ARTICLE XII
(1) Any pension [other than pension to which paragraph (1) of
Article X applies] and any annuity, derived from sources within one of the territories by
an individual who is a resident of the other territory and subject to tax in that other
territory in respect thereof shall be exempt from tax in the first-mentioned territory
provided that a pension or annuity payable from a superannuation fund approved or
recognised under the tax laws of either territory may be subjected to tax in that
territory.
(2) The term "pension" as used in this Article means periodic payments made in
consideration for services rendered or by way of compensation for injuries received.
(3) In this Article, the term "annuity" where it first appears means a stated
sum payable periodically at stated times during life or during a specified or
ascertainable period of time under an obligation to make the payment in return for
adequate and full consideration in money or money's worth.
ARTICLE XIII
A professor or teacher from one of the territories who receives remuneration for teaching, during a period of temporary residence not exceeding two years, at a university, college, school or other educational institution in the other territory, shall be exempt from tax in that other territory in respect of such remuneration.
ARTICLE XIV
(1) An individual who was resident of one of the territories and
is temporarily present in the other territory solely -
(a) as a student at a recognised university, college or school in that other territory, or
(b) as a business apprentice, or
(c) as the recipient of a grant, allowance or award for the primary purpose of study or
research from a religious, charitable, scientific, or educational organisation,
shall be exempt from tax in that territory in respect of-
(i) the remittances from abroad for the purposes of his maintenance, education, study,
research or training;
(ii) the grant, allowance or award; and
(iii) the remuneration from employment in that other territory.
(2) A resident of one of the territories who is temporarily present in the other territory
for a period not exceeding one year, as an employee of, or under contract with, an
enterprise of the former territory or an organisation referred to in subparagraph (c) of
paragraph (1), solely to acquire technical, professional or business experience from a
person other than such enterprise or organisation, shall be exempt from tax in that other
territory in respect of remuneration for such period.
(3) A resident of one of the territories temporarily present in the other territory under
arrangements with the Government of that other territory or any agency or instrumentality
thereof solely for the purpose of training, study or orientation shall be exempt from tax
in that other territory in respect of remuneration received by him on account of such
training, research or study.
ARTICLE XV
The provisions of the present Convention shall not be construed to deny or affect in any manner the right of diplomatic and consular officers to other or additional exemptions which may be granted to such officers.
ARTICLE XVI
Property may be subjected to wealth tax only in that territory where under the present Convention and according to the law of that territory income from such property may be subjected to tax.
ARTICLE XVII
(1) The laws in force in either of the territories shall continue
to govern the taxation of income and property in the respective territories except where
express provision to the contrary has been made in the present Convention.
(2) Subject to the provisions of the law of Pakistan regarding the allowance as a credit
against Pakistan tax of the tax payable in any country other than Pakistan, Ceylon tax
payable under the law of Ceylon and in accordance with the provisions of the present
Convention, whether directly or by deduction, in respect of income derived from Ceylon
shall be allowed as a credit against Pakistan tax. Where a resident of Pakistan receives
dividends paid by a company resident in Ceylon, Ceylon tax deductible under the provisions
of sub-section (4) of section 26 and sub-section (1) of section 27 of the Ceylon Inland
Revenue Act (No. 4 of 1963) shall be treated as tax payable by such resident of Pakistan
in respect of such dividends.
(3) Subject to the provisions of the Ceylon Inland Revenue Act (No. 4 of 1963), Pakistan
tax payable, whether directly or by deduction, by a person resident in Ceylon in respect
of income from sources within Pakistan, shall be allowed as a credit against any Ceylon
tax payable in respect thereof.
(4) For the purposes of the credit referred to in paragraph (2) of this Article, there
shall be deemed to have been paid as Ceylon tax-
(a) in addition to Ceylon tax payable under the provisions of sub-section (4) of section
26 of the Ceylon Inland Revenue Act (No. 4 of 1963) by a company resident in Pakistan, in
respect of dividends received by that company from a company resident in Ceylon as is
referred to in sub-section (1) of section 6 of the Ceylon Inland Revenue Act (No. 4 of
1963), the amount of Ceylon tax that would be payable if the provisions of sub-section (3)
of section 6 of the said Act did not apply:
Provided that the Ceylon tax so deemed to have been paid shall not exceed the amount of
Pakistan tax payable in respect of such dividends by the company resident in Pakistan less
the amount of the Ceylon tax payable; and
(b) the Ceylon tax which would be payable if sub-paragraphs (f) and (g) of sub-section (1)
of section 5 of the Ceylon Inland Revenue Act (No. 4 of 1963) did not apply.
(5) For the purposes of paragraph (3) of this Article, the term "Pakistan tax
payable" shall-
(a) include the agricultural income-tax imposed by the Government of any Province in
Pakistan and any tax of a substantially similar character imposed after the date of
signature of the present Convention by the Government of Pakistan or any Province or State
in Pakistan or by the Government of any territory to which the present Convention is
extended under Article XXIII;
(b) be deemed to include any amount which would have been payable as Pakistan tax for any
year but for an exemption granted for that year, or any part thereof, under -
(i) any of the following provisions or statutory rules, that is to say -
(aa) section 15BB of the Pakistan Income-tax Act;
(bb) clauses (xiii) and (xiv) of sub-section (3) of section 4 of the said Act; and
(ii) any other provision or statutory rule or notification which may subsequently come
into force granting in exemption which is agreed by the taxation authorities of the
Governments of the two territories to be of a substantially similar character, if it has
not been modified thereafter or has been modified only in minor respects so as not to
affect its general character.
(6) For the purposes of credit referred to in paragraphs (2) and (3) of this Article, in
addition to the reduced amount of tax payable in either territory on royalties under the
provisions of paragraph (2) of Article VIII of the present Convention, there shall be
deemed to have been paid by a resident of one of the territories in respect of such
royalties 25 per cent of the amount of the tax that would be payable in the other
territory if the aforesaid provisions of the present Convention did not apply · provided
that the amount of tax so deemed to have been paid in the other territory shall not exceed
the amount of tax payable on such royalties by such resident in the first-mentioned
territory less the reduced amount of tax payable in the other territory under the
provisions of paragraph (2) of Article VIII of the present Convention.
(7) Notwithstanding anything contained in paragraphs (2) and (3) of this Article, where
tax is imposed in both territories on income derived from sources outside both Pakistan
and Ceylon by a company which is resident in Pakistan for purposes of Pakistan tax and is
also resident in Ceylon for purposes of Ceylon tax, there shall be allowed against the tax
imposed in each territory a credit which bears the same proportion to the amount of that
tax (as reduced by any credit allowed in respect of the tax payable in the country from
which the income is derived) or to the amount of the tax imposed in the other territory
(reduced as aforesaid), whichever is the less, as the former amount (before any such
reduction) bears to the sum of both amounts (before any such reduction).
(8) Where in respect of any property situated in one of the territories wealth tax is
payable in both the territories by a resident of the other territory, the amount of such
tax payable in the first-mentioned territory shall be allowed as a credit against the
wealth tax payable in the other territory.
ARTICLE XVIII
(1) The competent authorities of either territory shall upon
request, exchange such information (being information available under the respective
taxation laws of the two territories) as is necessary, for carrying out the provisions of
the present Convention or for the prevention of fraud, or the like. in relation to the
taxes which are the subject of the present Convention. Any information so exchanged shall
be treated as secret and shall not be disclosed to any person other than those concerned
with the assessment and collection of the taxes which are the subject of the present
Convention. No information as aforesaid shall, however, be exchanged which would disclose
any trade, business, industrial or professional secret or any trade process.
(2) In no case shall the provisions of paragraph (1) be construed so as to impose upon the
Government of either territory the obligation to carry out administrative measures at
variance with its regulations and practice or which would be contrary to its sovereignty,
security or public policy or to supply particulars which are not procurable under the
legislation of that territory.
ARTICLE XIX
(1) Where a resident of one of the territories shows proof that
the action of the tax authorities of either territory has resulted or will result in
double taxation contrary to the provisions of the present Convention, he shall be entitled
to present his case to the competent authorities of the territory of which he is a
resident. Should his claim be deemed worthy of consideration, the competent authorities of
the territory to which the claim is made shall endeavour to come to an agreement with
the competent authorities of the other territory with a view to the avoidance of double
taxation.
(2) For the settlement of difficulties or doubts in the interpretation or application of
the present Convention or in respect of its relation to any Convention of the Government
of either of the territories with a third country, the competent authorities of the two
territories shall reach a mutual agreement as quickly as possible.
ARTICLE XX
The competent authorities of the two territories may consult together as may be necessary and communicate with each other directly for the purpose of giving effect to the provisions of the present Convention.
ARTICLE XXI
Regulations necessary to carry into effect the present Convention within the respective territories mar be prescribed in accordance with the laws of the said territories.
ARTICLE XXII
(l) The provisions of the present Convention shall not be
construed as restricting in any manner any exemption, deduction, credit or other allowance
accorded by the laws of either of the territories, whether before or after the date of
signature of the present Convention, in the determination of the tax imposed in such
territory or by any other Convention between the Contracting Governments.
(2) The nationals of one of the territories shall not, while resident in the other
territory, be subjected therein to any taxation or any requirement connected therewith
which is either higher or more burdensome than the taxation and connected requirements to
which the nationals of that other territory are, or may be, subjected.
(3) The enterprises of one of the territories the capital of which is owned, either wholly
or in part, or which is controlled, whether directly or indirectly, by one or more
residents of the other territory shall not be subjected in the first-mentioned territory
to any taxation or any requirement connected therewith which is either*, higher or more
burdensome than the taxation and connected requirements to which other similar enterprises
of the first-mentioned territory are, or may be subjected.
*The word "either" has wrongly appeared as "other" in the Official
Gazette.
(4) Nothing contained in paragraphs (2) and (3) of this Article shall be construed as-
(a) obliging either of the contracting Governments to grant to persons, not resident in
its territory, those personal allowances, reliefs and reductions which are, by law,
available to persons so resident; and
(b) affecting the provisions of paragraphs (3), (4) and (5) of Article VI of the present
Convention.
(5) In this Article, -
(a) the term "nationals" means -
(i) all individuals possessing the nationality of the respective territories; and
(ii) all other persons deriving their status as such from the laws in force in the
respective territories; and
(b) the term "taxation" means taxes which are the subject of the present
Convention.
ARTICLE XXIII
(1) The present Convention may be extended, either in its
entirety or with modifications, to any territory for whose international relations the
Government of either territory is responsible and which imposes taxes substantially
similar in character to those which are the subject of the present Convention and any such
extension shall take effect from such date and subject to such modifications and
conditions (including conditions as to termination) as may be specified and agreed to
between the contracting Governments in notes to be exchanged for this purpose.
(2) The termination in respect of Pakistan or Ceylon of the present Convention under
Article XXV shall, unless otherwise expressly agreed to by both contracting Governments,
terminate the application of the present Convention to any territory to which the
Convention has been extended under this Article.
ARTICLE XXIV
(1) The present Convention shall be ratified and the instruments
of ratification shall be exchanged as soon as possible at Islamabad.
(2) The present Convention shall come into force on the date of which the instruments of
ratification are exchanged and shall thereupon have effect -
(a) in Pakistan, for any year of assessment beginning on or after the first day of July,
1964, and
(b) in Ceylon, for any year of assessment beginning on or after the first day of April,
1964.
ARTICLE XXV
The present Convention shall continue in effect indefinitely, but
either of the contracting Governments may, on or before the 30th day of June in any
calendar year after 1970 give to the other contracting Government written notice of
termination and, in such event the present Convention shall cease to be effective -
(a) in Pakistan, for any year of assessment beginning on or after the first day of July in
the calendar year next following that in which the notice is given; and
(b) in Ceylon, for any year of assessment beginning on or after the first day of April in
the calendar year next following that in which the notice is given.
IN WITNESS WHEREOF, the undersigned duly authorised thereto, have signed the present
Convention and have affixed thereto their seals.
DONE in Colombo, this..............19th....................day of May, 1969 in four
originals, two in English, and two in Sinhala, all texts being equally authentic.
In the event of there being any dispute in the interpretation and the ratification of this
Convention, the English text shall prevail.
SD/- |
SD/- |
MAQBOOL ELAHI, PTS,
For Joint Secretary
C. No. 2(11)-TL/60.
Published in the Gazette of Pakistan, Extraordinary, dated 23-02-1970.
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