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" BASIC LEGAL FRAMEWORK OF BASIC LEGAL FRAMEWORK OF INTERNATIONAL TAXATION IN PAKISTAN--- NEXUS BETWEEN THE SOURCE AND RESIDENCE By Amjad Javaid Hashmi, Advocate High Court, Lahore 1. A leading expert on international tax planning Roy Sauders has cautioned that amature international tax planning is more likely than not lead to trouble. Yet many men of fortune the world over are fond of laying their hands a bit of international tax planning themselves. To better serve such hobbyists in Pakistan or those truly interested in it as students and tax professionals we have ventured to write this series of four articles for understanding the basic legal frame work of inter national taxation. We would like to understand, appreciate and focus on four major themes of international taxation as enshrined in the Income Tax Ordinance, 2001 (hereinafter the Ordinance). The themes are:-- (i) The principles for determining the nexus between the territorial source of income and the residential status of such income earning taxpayer and implications of tax rights and obligations flowing out of such nexus. (ii) The principles for taxing the foreign source income of residents. (iii) The principles for taxing the Pakistan source income of non residents. (v) The principles for avoiding double taxation of the same income source of a resident or a non-resident person in cross-territorial (Pakistan & Foreign) tax jurisdictions according to the dictates of avoidance of double taxation treaties. 2. Determination of nexus between the residential status of tax payer and territorial source of income is central to the subject of international taxation. We would like to begin with the first article in the series to appreciate the…