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Role of Double Taxation
Agreements

The international economic law could be studied with reference to the development of law relating to economics in its absolute terms or determination for the rules and regulations concerning with the economic and commercial relations between the subjects of all the countries world over. However, the second aspect is more relevant. With the increasing industrialisation of trade, commerce and the globalization of finance, production and technology, countries in the world cannot remain aloof from each other. The interdependence of the countries is so great that any economic imbalance in one country affects the economy in the other or influences its course. National policies have, therefore, become international-oriented. The national policies relating to fiscal matters nowadays do not ignore its international orientation. It is specifically reflected in the tax legislation. It is a well-known fact that any change in tax laws of a country has the effect of influencing its trade and economic relations with other countries. Therefore, each country exercises great care and caution in the formulation of its tax laws so as not to endanger its international economic interests. What is, therefore, relevant in the present day context is the interest of the nation's international economy. To avoid head on collision between these interests, some rules and regulations are required to be framed for the guidance of those nations.

Pakistan in the initial period of its existence overwhelmingly depended on domestic, rather than the world market. Its trade, therefore, had a stunted growth and grew less rapidly than the world trade. It was mainly in the early eighties that the Pakistani economy started opening up and the external sector started playing a significant role in the modernisation of industry and technological advancements. Till then the rate of technological progress had been abysmally low. For its economic growth, the purchase of technology is not the only option Pakistan has, to follow the route of foreign investment, joint ventures, etc. In its anxiety to encourage foreign investment, it is prepared to surrender its revenue for economic growth and thus forego taxes which could have been otherwise due, through the device of double taxation agreements.

Till March 31, 1998, Pakistan has concluded comprehensive tax treaties for avoidance of double taxation with the following 37 countries:

1. Austria 2. Bangladesh
3. Belgium 4. Canada
5. China 6. Denmark
7. Finland 8. France
9. Germany 10. Holland
11. Hungary 12. Indonesia
13. Ireland 14. Italy
15. Japan 16. Kazakhstan
17. Korea 18. Libya
19. Malaysia 20. Malta
21. Mauritius 22. Nigeria
23. Norway 24. Philippines
25. Poland 26. Romania
27. Singapore 28. Sri Lanka
29. Sweden 30. Switzerland
31. Thailand 32. Tunisia
33. Turkey 34. Turkmenistan
35. United Arab Emirates 36. United Kingdom
37. Uzbekistan

With the following eight countries double taxation agreements have been concluded for air/shipping business:

1. Greece (Shipping/Air Transport) 5. Kenya (Air transport)
2. India (Air transport) 6. Lebanon (Air transport)
3. Iran (Air transport) 7. Saudi Arabia (Air transport)
4. Jordan (Air transport) 8. USA (Shipping business)

The texts of double taxation agreements with above-mentioned countries are arranged in alphabetical order with each country constituting an independent portion in the book. It will help in smooth and error-free updating. The future changes and amendments with existing countries and new agreements will be provided through a quarterly up-dating service.

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