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Residences.6, s.7, s.81–s.84, s.101

Non-residents

Non-residents are taxed only on income from Pakistan. Royalty, fees and shipping income are taxed under a final regime on the gross amount.

Where it applies

  • Individuals in Pakistan for less than 183 days who don't meet the citizen tests, and foreign companies

How it works, step by step

The section of law behind each step is shown beside it.

  1. 1
    Check residences.82

    An individual is resident if in Pakistan for 183 days or more, or is a citizen who spent no more than 182 days in any other country, or who is not a tax resident of any other country.

  2. 2
    Find the sources.101

    Identify Pakistan-source income under the source rules.

  3. 3
    Apply the regimes.6, Div IV

    Royalty and fees for technical services: 15% gross, final. Other s.6 payments: 10%. PE income: the NTR.

  4. 4
    Treaty reliefs.107

    Apply the lower treaty rate with a tax residency certificate.

Rates and rules

CaseRate / ruleLaw
Royalty / fees for technical services / offshore digital services15% of grossDiv IV
Other s.6 payments10%Div IV
Shipping / air8% / 3% of grossDiv V

Worked example

A UK company paid Rs 10 million in Pakistan-source royalty: Rs 1.5 million is deducted as final tax, unless the treaty gives a lower rate.

Points to watch

  • Residents are taxed on worldwide income, with a credit for foreign tax (s.103).
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