Pakistan's Federal Board of Revenue has published the synthesized texts of the tax treaties with Saudi Arabia, Serbia, Singapore, Sweden, the United Arab Emirates, and the United Kingdom as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2006 Pakistan-Saudi Arabia tax treaty:

• in Pakistan:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 April 2021; and
  • with respect to all other taxes levied by Pakistan, for taxes levied with respect to taxable periods beginning on or after 1 October 2021; and
• in Saudi Arabia:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes levied by Saudi Arabia, for taxes levied with respect to taxable periods beginning on or after 1 October 2021.

Notwithstanding the above, Article 16 of the MLI (Mutual Agreement Procedure) has effect for a case presented to the competent authority of a Contracting State on or after 1 April 2021, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.

The MLI applies for the 2010 Pakistan-Serbia tax treaty:

• in Pakistan:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 April 2021; and
  • with respect to all other taxes levied by Pakistan, for taxes levied with respect to taxable periods beginning on or after 1 October 2021; and
• in Serbia:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes levied by Serbia, for taxes levied with respect to taxable periods beginning on or after 1 October 2021.

Notwithstanding the above, Article 16 of the MLI (Mutual Agreement Procedure) has effect for a case presented to the competent authority of a Contracting State on or after 1 April 2021, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.

The MLI applies for the 1993 Pakistan-Singapore tax treaty:

• in Pakistan:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 April 2021; and
  • with respect to all other taxes levied by Pakistan, for taxes levied with respect to taxable periods beginning on or after 1 October 2021; and
• in Singapore:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes levied by Singapore, for taxes levied with respect to taxable periods beginning on or after 1 October 2021.

Notwithstanding the above, Article 16 of the MLI (Mutual Agreement Procedure) has effect for a case presented to the competent authority of a Contracting State on or after 1 April 2021, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.

The MLI is not yet effective for the 1985 Pakistan-Sweden tax treaty. Although both countries have deposited their ratification instruments for the MLI, Sweden has taken the reservation that it must deposit a notification that it has completed its internal procedures for the entry into effect of the MLI for a particular covered agreement. Sweden has not yet deposited such notification. Once the notification is deposited, the MLI will generally apply:

• with respect to taxes withheld at source on amounts paid or credited to non-residents, from the first day of the year beginning on or after 30 days after the date of deposit of the notification; and
• with respect to all other taxes, from the taxable period beginning on or after the expiration of a six-month period from 30 days after the date of deposit of the notification.

The MLI applies for the 1993 Pakistan-United Arab Emirates tax treaty:

• in Pakistan:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 April 2021; and
  • with respect to all other taxes levied by Pakistan, for taxes levied with respect to taxable periods beginning on or after 1 October 2021; and
• in the United Arab Emirates:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes levied by the United Arab Emirates, for taxes levied with respect to taxable periods beginning on or after 1 October 2021.

Notwithstanding the above, Article 16 of the MLI (Mutual Agreement Procedure) has effect for a case presented to the competent authority of a Contracting State on or after 1 April 2021, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.

The MLI applies for the 1986 Pakistan-United Kingdom tax treaty:

• in Pakistan:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 April 2021; and
  • with respect to all other taxes levied by Pakistan, for taxes levied with respect to taxable periods beginning on or after 1 October 2021; and
• in the United Kingdom:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes levied by the United Kingdom, for taxes levied with respect to taxable periods beginning on or after 1 October 2021.

Notwithstanding the above, Article 16 of the MLI (Mutual Agreement Procedure) has effect for a case presented to the competent authority of a Contracting State on or after 1 April 2021, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.