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" BASIC LEGAL FRAMEWORK OF INTERNATIONAL     BASIC LEGAL FRAMEWORK OF INTERNATIONAL TAXATION OF PAKISTAN - II   Taxing Pakistani & Foreign Income Sources of Residents   By   Amjad Javed Hashmi, Advocate, High Court, Karachi   1. Legal burden to pay income tax directly falls upon a person i.e. a technical concept having very broad scope and effect as defined in section 80 of the Income Tax Ordinance, 2001 (the Ordinance). Every taxpayer has to be a person first. Most popular variations of the technical concept of a person include an individual and all its types, an association of person and all its types and a company and all its types as recognized in a given tax statute. Rights and obligations of a person are, in direct tax jurisdictions all over the world, consequently dependant upon his, its tax domicile (parallel to political domicile ) or residential status and territorial sources of income. In the age of globalization and information technology; the interaction and frequency of economic interests of taxpayers have become borderless and more and more people are deriving income 'from multiple territories i.e their homeland as well as from other countries.   In the above background taxation of foreign source income of the persons resident of (tax domiciled in) Pakistan is inviting growing attention of tax authorities and the tax practitioners alike. It is the second major subject of the laws of international taxation in Pakistan. It recognizes and deals with two key foreign sources of a resident person: (i) salary sources and non-salary sources. Section 102 reflects upon the taxation of foreign source salary income of a resident individual. Section 103 postulates the taxation of foreign source non salary income of a resident…
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