S.R.O. 714(I)/2006, Islamabad, the 13th July ,2006

SROS: S.R.O. 714(I)/2006, Islamabad, the 13th July ,2006 AMENDMENT SHALL BE MADE IN THE INCOME TAX RULES, 2002, THE SAME HAVING BEEN PREVIOUSLY PUBLISHED AS REQUIRED BY SUB-SECTION(3) S.R.O. 714(I)/2006, Islamabad, the 13th July ,2006:- In exercise of the powers conferred by sub-section(1) of section 237 of the Income Tax Ordinance, 2001(XLIX of 2001), the Central Board of Revenue is pleased to direct that the following further amendment shall be made in the Income Tax Rules, 2002, the same having been previously published as required by sub-section(3) of the said section. In the aforesaid Rules, after rule 19, the following new rule shall be inserted, namely:- 19A. Application or initiation of Mutual Agreement Procedure(MAP).-(1) Where a resident taxpayer , or a Pakistani national residing abroad is aggrieved by any action of the tax authorities of any country outside Pakistan with which Pakistan has signed an Agreement for the Avoidance of Double Taxation for the reason that, according to him, such action is not in accordance with the terms of the agreement with such other country outside Pakistan, he may make an application to the Competent Authority in Pakistan seeking to invoke the provision of the Mutual Agreement Procedure, if any, provided therein, in the Form prescribed in rule 19C. (2) The Competent Authority of Pakistan upon satisfaction that,- the taxpayer has reasonable grounds to justify Competent Authority assistance; the application has been made within two years from the date of notification of the cause of grievance; and the double taxation or other impending grievance is more than a mere possibility; shall cause to take up the matter with the Competent Authority of the country concerned and end favor to resolve the matter through consultative measures. In case the Competent Authority in Pakistan decides not to intervene in the matter, it will inform the taxpayer applicant, within thirty days of the receipt of the application, of its decision and grounds thereof in writing. If during the course of mutual agreement proceedings, the Competent Authority of the other country requires any clarification, verification of facts, or guarantees, that…