Tax residence in Pakistan for U.S. citizens and green card holders

Pakistan treats you as a resident individual for its tax year (1 July – 30 June) if you are present there 183 days or more, if you are a Federal or Provincial Government employee or official posted abroad, or — since tax year 2023 — if you are a Pakistani citizen, unless you spent more than 182 days in one other country in that year and are a resident taxpayer there (s. 82 of the Income Tax Ordinance, 2001). The United States taxes its citizens and green card holders as residents wherever they live, and other individuals under the substantial presence test (183 weighted days over three years, with at least 31 in the current year). The 1957 U.S.–Pakistan Convention has no tie-breaker and no saving-clause article: a person resident in both countries under their laws is a treaty resident of neither (Art. II(1)(h)–(i)), and a U.S. citizen can never be a “resident of Pakistan” under it. Both countries may then tax your worldwide income, and double tax is relieved only by credits (Art. XV) and by Pakistan's exemption of foreign salary on which tax was withheld and paid abroad (s. 102).

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Free, no sign-up, about 3 minutes. Conclusion under U.S. law, compared with the law of Pakistan and the tax treaty.

When Pakistan treats you as a tax resident

Pakistan's tax year runs from 1 July to 30 June. 183 days or more in Pakistan in that period — counting all stays together — make you a resident individual, whatever your nationality.

Federal and provincial government employees and officials posted abroad — for example to the United States — remain resident in Pakistan whatever the number of days.

Since tax year 2023 a Pakistani citizen can be resident with fewer than 183 days in Pakistan.

You were in Pakistan for 183 days or more in the tax year (1 July – 30 June) — under s. 82(a) of the Income Tax Ordinance, 2001 you are a resident individual and Pakistan taxes your worldwide income, including income from the United States.
You are a Federal or Provincial Government employee or official of Pakistan posted abroad — under s. 82(c) you are a resident individual for the whole tax year, however few days you spent in Pakistan.
You are a Pakistani citizen and in the Pakistani tax year you were not present in any other country, the United States included, for more than 182 days — under s. 82(d) you are a resident individual of Pakistan even with fewer than 183 days there.
You are a Pakistani citizen and no other country treats you as its resident taxpayer — under s. 82(d) you remain a resident individual of Pakistan even though you spent fewer than 183 days there.

When you are a nonresident

You are not a Pakistani citizen and spent fewer than 183 days in Pakistan in the tax year — you are a non-resident: Pakistan taxes only your Pakistan-source income.
You spent fewer than 183 days in Pakistan, you were present in another country for more than 182 days, and a country other than Pakistan treats you as its resident taxpayer — under s. 82 you are a non-resident: Pakistan taxes only your Pakistan-source income.

Where the rules of Pakistan clash with U.S. tax rules

Collision: resident in both countries — the 1957 Convention has no tie-breaker. If Pakistan treats you as resident (183 days, the citizen rule or a government posting) and the United States does too (citizenship, green card or substantial presence), no article assigns you to one country: you are a treaty resident of neither, and both tax your worldwide income. Double tax is relieved only by credits: the United States credits Pakistani tax on Pakistan-source income (Art. XV(1); Form 1116), and Pakistan credits U.S. tax on U.S.-source income (Art. XV(2); s. 103); salary for work in the U.S. on which U.S. tax was withheld and paid is exempt in Pakistan (s. 102). If you are still taxed twice, you may present the facts to either tax authority, which «shall endeavour» to agree on avoiding it (Art. XVI(2)); they do not decide your residence.
Collision: Pakistani citizen in the U.S. — resident of Pakistan with fewer than 183 days. Since tax year 2023 a Pakistani citizen is resident in Pakistan unless he or she was present in another country for more than 182 days in the Pakistani tax year (1 July – 30 June) and is a resident taxpayer of another country (s. 82(d)). If you live in the United States but were not there for more than 182 days within Pakistan's year, or the U.S. does not treat you as a resident taxpayer, Pakistan also treats you as resident — and the 1957 Convention has no tie-breaker. The U.S. counts days per calendar year, so one Pakistani tax year spans two U.S. years. Proof of U.S. residence is IRS Form 6166 (requested on Form 8802); keep a day-by-day travel record as well.
Collision: 183 days in Pakistan's tax year while resident in the U.S.. 183 days in Pakistan between 1 July and 30 June make you resident in Pakistan. A U.S. citizen or green-card holder stays a U.S. resident at the same time, and in the year of a move you may also meet the U.S. substantial presence test. There is no treaty tie-breaker: both countries may tax your worldwide income for the overlapping period, and double tax is relieved by credits (Art. XV; s. 103).

What else to know

Which treaty applies: the 1957 U.S.–Pakistan Convention — no tie-breaker. The Convention signed at Washington on 1 July 1957 (ratifications exchanged on 21 May 1959; applies from 1959) is still in force; the United States is not an MLI party, so the MLI does not modify it. It defines a «resident of the United States» as a person resident in the U.S. and not in Pakistan, and a «resident of Pakistan» as a person — other than a U.S. citizen — resident in Pakistan and not in the U.S. (Art. II(1)(h)–(i)). There is no tie-breaker and no saving-clause article. Employment: Art. XI (temporary presence of up to 183 days in the taxable year); relief: Art. XV (credit in both countries; the tax-sparing sentence was not ratified by the U.S. Senate); consultation: Art. XVI(2).
Working in Pakistan while resident in the U.S.: Art. XI. Salary for work done in Pakistan is Pakistan-source income wherever it is paid (s. 101). If you are a «resident of the United States» under the Convention (resident in the U.S. and not in Pakistan), Pakistan does not tax it only if you are temporarily present in Pakistan for not more than 183 days in the taxable year, the work is done for or on behalf of a U.S. resident, and the pay is subject to U.S. tax (Art. XI). Otherwise Pakistan can tax the pay for your days of work there, usually by withholding, and the United States credits the Pakistani tax (Art. XV(1)).
How double tax is relieved between the U.S. and Pakistan. The United States credits Pakistani tax on Pakistan-source income against U.S. tax on that income (Art. XV(1); Form 1116 — see the U.S. section). If Pakistan taxes you as a resident, it credits U.S. tax on U.S.-source income up to the Pakistani tax on that income at your average rate, separately for each head of income, with no carry-forward (Art. XV(2); s. 103); foreign salary on which tax was withheld and paid abroad is exempt in Pakistan (s. 102). To prove tax paid in Pakistan, ask FBR's Competent Authority for a certificate of tax paid (rule 19B).
Non-resident of Pakistan: what Pakistan still taxes. As a non-resident you pay Pakistani tax only on Pakistan-source income: salary for work done in Pakistan or paid by a Pakistani government; rent and gains on property in Pakistan; dividends of Pakistani companies; profit on debt, royalties and fees paid by Pakistani residents; gains on Pakistani shares. Tax is mostly withheld by the payer, often as final tax; check whether the 1957 Convention limits Pakistani tax on the item concerned (proof of U.S. residence: IRS Form 6166). To claim the U.S. foreign tax credit, ask the Competent Authority for a certificate of tax paid in Pakistan (rule 19B).
Pakistani citizen moving to the U.S.: part-year rules. Pakistan has no split year: residence is fixed for the whole tax year (1 July – 30 June). A citizen who leaves Pakistan during a tax year and stays abroad for the rest of it is exempt on salary earned abroad in that year (s. 51(2)). If you leave with no intention of returning, notify the Commissioner at least 15 days before departure and file a return up to that date (s. 145). A citizen who returns after four non-resident years is exempt on foreign-source income in the year of return and the next year (s. 51(1)). The United States taxes citizens and green-card holders for the whole calendar year.
Foreign employee in Pakistan for up to three years (s. 50). If you are resident in Pakistan only because of your employment and are present for no more than three years, your foreign-source income — for example rent or interest from the United States — is exempt in Pakistan, except income from a business established in Pakistan and foreign income brought into or received in Pakistan. Your salary for work in Pakistan remains taxable there. A U.S. citizen or resident is still taxed in the U.S. on worldwide income, with a credit for Pakistani tax.
Pakistani government employees posted to the United States. An employee or official of the Federal or a Provincial Government of Pakistan posted abroad stays resident in Pakistan (s. 82(c)), and the government salary is Pakistan-source income (s. 101). Art. IX of the Convention exempts from U.S. tax certain remuneration paid by the Government of Pakistan to Pakistani citizens — check its conditions, and the rules for diplomats and consular staff, with your mission.
No U.S.–Pakistan social security (totalization) agreement. The United States has no totalization agreement with Pakistan, so U.S. Social Security and Medicare taxes (or self-employment tax) apply under U.S. law and no certificate of coverage can exempt a posted worker from either system.

How dual residence is resolved

If both countries treat you as a resident, Art. II(1)(h)–(i) (no tie-breaker) of the treaty applies: Convention between the United States of America and Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Washington on 1 July 1957). The tests are applied in order — permanent home, center of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities. U.S. citizens remain taxable in the United States under the saving clause.

Terms you will come across in Pakistan

resident individual: 183 days in the tax year, a government posting abroad, or the citizen rule of s. 82(d)
tax year: 1 July to 30 June; tax year 2027 runs from 1 July 2026 to 30 June 2027
Pakistan-source income: the only income taxed for a non-resident (s. 101)
foreign income and assets statement: required with foreign income of USD 10,000 or more or foreign assets of USD 100,000 or more (s. 116A)
certificate of tax paid: issued by the Competent Authority of Pakistan for the tax authority of your country of residence (rule 19B)
Income Tax Ordinance, 2001: Pakistan's income tax law

Questions

I am a U.S.–Pakistani dual citizen living in Pakistan — which country is my residence under the treaty?

Neither. The 1957 Convention has no tie-breaker, and a U.S. citizen can never be a “resident of Pakistan” under it (Art. II(1)(i)), so you remain resident in both: the United States taxes your worldwide income as a citizen, Pakistan as a resident. The United States credits Pakistani tax on Pakistan-source income (Art. XV(1); Form 1116), and Pakistan credits U.S. tax on U.S.-source income up to the Pakistani tax at your average rate (Art. XV(2); s. 103). If you are still taxed twice, you may present the facts to either tax authority (Art. XVI(2)), but they do not decide your residence.

I am a Pakistani citizen living in the U.S. — can Pakistan still treat me as resident?

Yes. Since tax year 2023 a Pakistani citizen is resident in Pakistan unless he or she spent more than 182 days in one other country in the Pakistani tax year (1 July – 30 June) and is a resident taxpayer there (s. 82(d)). The U.S. counts days per calendar year, so one Pakistani tax year spans two U.S. years; keep a day-by-day travel record and IRS Form 6166 (requested on Form 8802) as proof of U.S. residence. Salary for work in the United States on which U.S. tax was withheld and paid is exempt in Pakistan (s. 102).

How long can I work in Pakistan for a U.S. employer before Pakistan taxes my salary?

Salary for work done in Pakistan is Pakistan-source wherever it is paid (s. 101). If you are a “resident of the United States” under the Convention — resident in the U.S. and not in Pakistan — Pakistan does not tax it only if you are temporarily present in Pakistan for not more than 183 days in the taxable year, the work is done for or on behalf of a U.S. resident, and the pay is subject to U.S. tax (Art. XI). There is no U.S.–Pakistan totalization agreement, so no certificate of coverage can exempt a posted worker from either social security system.

Sources

Legislation and official guidance

Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Income Tax Ordinance, 2001, s. 81 — A person is a resident person for a tax year if a resident individual, resident company or resident AOP for the year (or the Federal Government); a person is non-resident for a tax year if not resident for that year.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; FBR consolidated text amended up to 30.06.2026) — A citizen of Pakistan is also a resident individual if he or she is not present in any other country for more than 182 days during the tax year, or is not a resident taxpayer of any other country. Applies from tax year 2023.
PwC Worldwide Tax Summaries — Pakistan, Individual: Residence (reviewed 24 Aug 2026) — Three tests: 183 days or more in the tax year; Federal or provincial government employee posted outside Pakistan; a citizen who is not present in any other country for more than 182 days in the tax year or is not a tax resident of any other country.
Art. II(1)(h)–(i) of the U.S.–Pakistan Convention (1957)
Art. XI of the U.S.–Pakistan Convention (1957)
Art. XV of the U.S.–Pakistan Convention (1957)
Art. XVI(2) of the U.S.–Pakistan Convention (1957)
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
IRS — Form 6166, Certification of U.S. tax residency
§ 7701(b)(3)(A); Treas. Reg. § 301.7701(b)-1(c)
Income Tax Ordinance, 2001, s. 101 — Salary is Pakistan-source to the extent it is received from employment exercised in Pakistan (wherever paid) or is paid by or on behalf of the Federal, a Provincial or a Local Government in Pakistan (wherever the employment is exercised). Dividends of resident companies, profit on debt and royalties paid by residents, rent and gains on immovable property in Pakistan, gains on shares of resident companies and pensions paid by residents are Pakistan-source; everything else is foreign-source.
Income Tax Rules, 2002, rule 19B — A non-resident may apply to the Competent Authority of Pakistan for a certificate of tax paid in Pakistan (by deduction, collection or otherwise) for presentation to the tax authority of the country of residence; proof of residence in that country is required.
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
Income Tax Ordinance, 2001, s. 145 — A person likely to leave Pakistan during or shortly after a tax year with no intention of returning must notify the Commissioner at least 15 days before departure and file a return for the period up to departure; the Commissioner may also require such a return by notice.
Income Tax Ordinance, 2001, s. 50 — Foreign-source income of an individual who is resident solely by reason of employment and present in Pakistan for not more than three years is exempt — except income from a business established in Pakistan and foreign-source income brought into or received in Pakistan.
Art. IX of the U.S.–Pakistan Convention (1957)
SSA — U.S. international social security agreements (status)
Income Tax Ordinance, 2001, s. 116A — A resident individual with foreign income of at least USD 10,000 or foreign assets of at least USD 100,000 must furnish a foreign income and assets statement (foreign assets and liabilities at year-end, transfers, foreign income and related expenditure).
KPMG Pakistan — A brief on Finance Act 2026 — The Finance Act, 2026 was enacted on 27 June 2026; its amendments to the Income Tax Ordinance, 2001 take effect from 1 July 2026 (tax year 2027) unless otherwise provided.
Vialto Partners — Pakistan: Finance Bill 2026-27 summary (employment tax) — Salary slabs for tax year 2027: 0% up to Rs 600,000, then 1%, 11%, 20%, 25%, 29%, 32% and 35% above Rs 7,000,000; the 9% surcharge (s. 4AB) on salary income above Rs 10 million withdrawn; maximum rate for non-salaried individuals stays at 45%.
FBR — Bilateral full scope treaties (list of Pakistan's comprehensive double taxation agreements) — List of the countries with which Pakistan has comprehensive (full scope) double taxation agreements.
Text of the Convention (transcription with the 1959 proclamation and Senate reservation; gocodebook.com) — Signed at Washington 1 July 1957; ratifications exchanged at Karachi 21 May 1959; applies to U.S. taxable years beginning on or after 1 January 1959 (Art. XIX).

Updated 2026-11-04. The result is for information only and is not tax or legal advice. Tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes. Consult a qualified adviser before making decisions.

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