S.R.O. 82(I)2023, Islamabad, the January 30th, 2023

GOVERNMENT OF PAKISTAN REVENUE DIVISION Islamabad, the January 30th, 2023 NOTIFICATION (Income Tax) S.R.O. 82(I)2023.- WHEREAS the Islamic Republic of Pakistan and the Republic of Tajikistan signed the Protocol on 17th September 2021, as set out in the Annexure to this Notification (the Protocol) to amend the existing Convention for tire Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income between Pakistan and Tajikistan signed in Islamabad on May 13, 2004; Whereas, in terms of Article 2 of the Protocol “The Contracting State shall notify each other through diplomatic channels that all legal procedures for the entry into force of this Protocol have been completed”, and “This Protocol shall enter into force on the date of the later of the notifications”. Authorities of Tajikistan have notified the Protocol with effect from 17th June, 2022; NOW, THEREFORE, in exercise of the powers conferred by sub-section (1) of section 107 of the Income Tax Ordinance, 2001 (XLIX of2001), the Federal Government is pleased to direct that the provisions of the said Protocol shall come into force from 17th June, 2022 and the provisions of the said Protocol shall apply, (a) in case of the Islamic Republic of Pakistan, from the 1st day of July next following the date upon which the Protocol enters into force; and (b) in case of Republic of Tajikistan, from the 1st day of July following the date upon which the Protocol enters into force. PROTOCOL BETWEEN THE GOVERNMENT OF THE ISLAMIC REPUBLIC OF PAKISTAN AND THE GOVERNMENT OF THE REPUBLIC OF TAJIKISTAN AMENDING THE CONVENTION FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME SIGNED IN ISLAMABAD ON MAY 13, 2004 The Government of the Islamic Republic of Pakistan and the Government of the Republic of Tajikistan, Desiring to conclude a Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed in Islamabad on May 13 2004 (hereinafter referred to as “The Convention”), Have agreed as follows: Article 1 Article 25 of the Convention shall be replaced by the…