Comperative DTTs of Pakistan

Transcription

1 Comperative DTTs of Pakistan S. No. COUNTRY CONTINENT Republic/Dem ocratic/kingdo m/sultanate P.E. BUSINESS PROFIT SHIPPING AIR TRANSPORT DIVIDEND INTEREST ROYALITIES FEE FOR TECHNICAL SERVICES CAPITAL GAIN IND. PERSONAL SERVICES OTHER TAX TAX INCOME CREDIT SPARING 6 months period existence of building 50% reduced rate at Taxed at placed of 10% 10% 1 Austria Europe sites etc. source effective management Coy 10% Other situated Fixed base 183 days location credit it. Tax Sparing. Taxes where capital assets is property income taxed in place of For Pakistan tax Austria will give tax 2 Azerbaijan Asia Building project continuous 6 months service consultancy 183 days aggregate. shipping, boats including container rentals etc. in international traffic Taxable in Fixed base or stay source 183 days property taxed Tax Credit where situated 3 Bangladesh Asia Building site 183 days 50% reduction in Tax at source Taxable in 120 days stay or source fixed base property taxed where situated countries Tax Sparing 4 Balgium Europe i) Ii) Services consultancy 3 months in fiscal year. Payment made by Pakistani coy. To Belg. Coy. 10% & other. 20% & Taxed in source i) Fixed base ii) 183 days iii) Payments i) exceeding Rs.50,000 property taxed in fiscal year. where situated Pakistan gives tax credit to Tax Sparing Belgium tax. to Pakistan. 10% 183 days = = 5 Belarus Europe Coys. 10% Other -- 10% 20% 10% = = 6 Bosnia Asia -- 10% = = 7 Bahrain Asia 8 Brunei Asia months Services 3 10% available. Tax sparing is available. 9 Canada America X x x x x x x x x x x x x

2 10 China Asia X x x x x x x x x x x x x 11 Denmark Europe Taxed at 50% reduced rates 12% Source 183 days or Rs.75,000 or faxed base property where situated. available. Tax sparing was to Pakistan. 12 Egypt Africa Building site more than 3 Coy. Other 30% 10% Both Status property where tax situated. credit. Tax sparing 13 Finland Europe - Services & consultancy 6 months aggregate. 50% reduction in tax in source including containers. 12% coy. and capital others 20% others. Bank 10% Other 10% 10% property where situated.. 14 France Europe Building site installation project management for 183 days international traffic. Coy. 10% Other for dividend, interest royalty for 10 years. 15 Germany Europe (also protocol). Effective management. Effective management. Coy. 10% Other Other 20% Bank 10% 120 days or fixed 10% 10% with condition.. 16 Greece Europe Limited purposes agreement. On registration basis. Effective management. LIMITED PURPOSES AGREEMENT 17 Holland/Nether land Europe months consultancy Bank 10% Coy. Oth 5% (coy Attribution to Article i)183 days or ii) property at to Tax Sparing for service 4 (also protocol). Coy. 10% Other Other 20% right etc) 7 or 14 Source iii)fixed base Pakistan tax certain taxes. 50% reduction in tax at Where property base or payment property at Tax Sparing 18 Hungary Europe source Coy. Other 20% situated. made by resident. Hungary 19 India Asia Limited purposes agreement. including interest. Only Air income treaty. 20 Indonesia Asia Building sites 3 Taxed in source as per domestic law. Coy. 10% Other Where property i) 90 days situated. fixed base at on proportionat Tax Sparing e basis.

3 21 Iran Asia Building sites 12 Exempt Exempt 5% 10% 10% - Where property situated. Taxed in source is is. 22 Ireland Europe Building sites 12, other than internal operations., other than internal operations. Coy. 10% Resident nil Other normal Exempt if taxed in the of resident. - Where property situated. 183 days Italy Europe Consultancy Source tax to service 3 be reduced by 50% Source tax to be reduced by 50% Coy. Other 25% 30% reduceable according to other OECD 30% reduceable according to other OECD Taxable both States (Art.22) Location of Property. Fixed base or stay 183 days or Rs property at income. Tax Sparing countries upto 25% of payable tax. 24 Japan Asia Fixed place of Taxed in source business. except internal. Exemption for industrial loans. Other 30% - - Exempt if stay is less then 183 days & payments made by resident of his State or less than 90 days and payment less than yen. property at Limited tax sparing. 25 Jordan Asia Service 3 Exempt 50% reduction at source 10% 183 days Attribution to fixed base remuneration 1500 US$ in source 26 Kazakhstan Asia 6 months period Coy. 12.5% Other 12.5% Taxable in Fixed base or 183 source days stay. property where Tax Sparing located. 27 Kenya Africa Air Transport treaty only Korea Asia Building site project 6 50% reduction in tax by source Coy. 10% Other 12.5% 12.5% 10% 10% Tax Sparing Where property Fixed base 183 days property where proportionat for dividend, situated. US$ 10,000. located. e interest & Services 3 29 Kyrgyz Republic Asia Exempt Exempt days source in 30 Kuwait Asia Exempt Exempt -- Reduced by 50% base 183 days Lebanon Asia Services 3 Exempt Exempt 10% 10% 7.5% days in source

4 Effective management Effective management 32 Libya Africa Fixed place. basis. basis. Taxable on where the Taxable where coy. Is registered. arises. Fixed base attribution where located.. 33 Lithuania Europe X X X X X X X X X X X X X 34 Malaysia Asia Exempt except Building site which operations source exist for more than 6 Exempt except operations within source Coy. Other 20% Taxable as per domestic law. Where property Stay 183 days or situated. US$3000 to be taxed where Proportionat Tax Sparing located. e tax credit. 35 Malta Africa Building site supervisory activity which exist for more Exempt including than 12 container rentals etc. 10% 10% base or P.E Place of Fixed base Given by property where both located. credit. X X 36 Mexico America X X X X X X X X X X X 37 Morocco Africa Services 1 month. 10% based 183 days. Source 38 Mauritius Africa 10% 10% 12.50% base or P.E Taxable where located. Fixed base 183 days Proportionat where situated. e tax credit. 39 Nigeria Africa Building site 3 months supervisory 3 months or 10% of In case of operation by In case of operation by sale price of sale of one enterprise of any one enterprise of any machinery. state 1%. state 1%. Coy. 12.5% Other As per domestic law Fixed base Related to effective 40 Norway Europe Fixed base 183 days expired. Norway 10% 12% 12% 41 Nepal Asia Building sites 183 days. Services 183 days. 10% 12.50% 12.50% 42 Oman Asia Attribution to fixed base Exempt Exempt Coy. 10% Other 12.5% base is is.

5 43 Philippines Asia months consultancy 90 days assembly etc. 40% reduction in tax in 40% reduction in tax in 3 source source Coy. Other 25% in preferred areas others 25% In source Fixed base or 90 days Taxable in source 44 Poland Europe Building site 12 unless internal unless internal operations. operation. Taxable except approval loan. 20% Exempt 183 days credit. 45 Portugal Europe Exempt Exempt Coy. 10% Other Qatar Asia unless internal unless internal operations. operations. Coy. 5% Other 10% Fixed base or 183 days 47 Romania Europe Other 10% 10% 12.50% days in source -Commission 10% 48 Saudi Arabia Asia Coy. 5% Other 10% 10% 10% -- base 183 days 30000US$ in source -Commission 10% 49 Senegal Africa X X X X X X X X X X X X X 50 Serbia Asia X X X X X X X X X X X X X 12.50% 10% 10% Building sites 50% reduction in tax in Industrial Coy.10% Coys12.5% All other property in Limited tax sparing Proportionat credit by 51 Singapore Asia installation 183 days. source 183 days source e tax credit. both Singapore 52 Sri Lanka Asia Agricultural or forming estate building site services 50% reduction in tax in 183 days. source 10% 20% days. -do 53 Sweden Europe 10% 10% Building sites or supervisory activity 6 at 50% reduced rates. Fixed base or 183 days or 60,000 Swedish Crone. Proportionat e tax credit. credit.

6 54 Switzerland Europe Coy. 10% Other 20% Building sites or supervisory activities at 50% reduced at 50% reduced 6 rate. rate. Stay more than 183 days. Attribution to PE Conditional Tax sparing South Africa Africa Exempt Exempt 183 days Attribution to fixed in Tax Credit source 56 Spain Europe X X X X X X X X X X X X X 57 Sudan Africa Service 3 Taxed at place of Taxed at place of effective effective 10% 20% = = 58 Syria Asia 10% 10% 18% patent trade mark & industrial concern is copy right & literary is 10% -- in source - May be taxed in road transport source Attribution 183 days exempt Thailand Asia Building sites and services 183 days. Exempt Exempt Coy. Other 25% Bank 10% Other 25% 10% 20% Taxable at source Stay 183 days or fixed base source 60 Tunisia Africa Building site 3 10% 13% 10% 10% days stay. 61 Turkey Asia 10% 10% Coy. 10% Other -- days. Building site 12 months - services 183 Exempt including container rentals etc. unless operated in 62 Turkmenistan Asia days. source Domestic law days stay. exempt. source Road & Railways 10% 10% Tajiskistan Asia effective effective Coy. 5% Other 10% 6000 Pak Rs. = = 64 UK Europe Coy. Other 20% 12.50% 12.50% Source in Fixed source with condition. Tax sparing for source of income for first 10 years from the date of exemption granted to such source in Pakistan.

7 65 U.A.E. Asia unless Taxed in source operated in internally. Coy. 10% Other 10% 12% 12% days. credit. 66 U.S.A. America Fixed place of business. "D" -- Exempt Stay 183 days Uzbekistan Asia Exempt including container rentals etc. 10% 10% in source - May be taxed in Fixed base or stay 90 road transport -- source days exempt. 68 Ukraine Europe 10% 10% months Service 3 management management Coy. 10% Other -- base US$19000 = = 69 Venezula America X X X X X X X X X X X X X 70 Vietnam Asia Building sites & supervisory activities 6 Place of registration Place of registration base 183 days US$1500 = = 10% 71 Yemen Asia 183 days = =