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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State, of a Land or a political sub-division or local authority thereof, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on capital appreciation and taxes on the total amounts of wages or salaries paid by enterprises.

(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) in the Islamic Republic of Pakistan:
    • (1) the Income Tax;
    • (2) the Super Tax;
    • (3) the Surcharge Tax;
  • (hereinafter referred to as "Pakistan Tax").
  • (b) in the Federal Republic of Germany:
    • (1) the Einkommensteuer (income tax);
    • (2) the Korperschaftsteuer (corporation tax); and
    • (3) the Gewerbesteuer (trade tax);
  • (hereinafter referred to as "German tax");

(4) The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of the existing taxes by either Contracting State or by the Government of any territory to which the present Agreement is extended under Article 27 of this Agreement. At the end of each year, the competent authorities of the Contracting States shall notify each other of changes of a substantial nature which have been made in their respective taxation laws.