DoubleTaxationUnited States – Pakistan tax treaty: residence, 183 days, rates
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)
- Signed: 1957-07-01
- In force since: 1959-05-21
- Official text
If both countries treat you as resident
- «Resident of the United States»: an individual resident in the United States for U.S. tax purposes and not resident in Pakistan for Pakistan tax purposes. «Resident of Pakistan»: a person (other than a U.S. citizen or U.S. corporation) resident in Pakistan for Pakistan tax purposes and not resident in the United States for U.S. tax purposes. The Convention has no tie-breaker article: a person resident in both countries under their laws is a treaty resident of neither. Art. II(1)(h)–(i) of the U.S.–Pakistan Convention (1957)
Income: who taxes it
| Income | Treaty rule | Article |
|---|---|---|
| Salary (employment) | The country where the work is done may tax it. Exempt if all apply: no more than 183 days in the tax year; the employer is not resident there. | Art. XI |
| Self-employment, business, services | Country of residence; the other country taxes profits of a permanent establishment (fixed base) there, or if your stay there reaches 183 days in the tax year. | Art. III, Art. XI |
| Pension | The source country may tax; the country of residence relieves double taxation. | Art. X |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. IX |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. IX |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | no article (domestic law of the situs State applies) |
| Dividends | The source country may tax; the country of residence relieves double taxation. | Art. VI(1); Art. VII |
| Interest (deposits, bonds, loans) | The source country may tax; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | no article (only Art. XIV, central banks) |
| Royalties (copyright, licences) | Only the country of residence. | Art. VIII(1) |
| Sale of property or shares | Real estate: the country where it is located may tax. Shares of companies deriving their value mainly from real estate: the same. Other property: under certain conditions the source country may also tax (see the article). | no article (domestic law) |
| Other income | The source country may tax; the country of residence relieves double taxation. | no other-income article |
How double taxation is relieved
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. XV(2)
- United States: credit for the tax paid in the source country, up to the country’s own tax on that income Art. XV(1)
Data checked: 2026-11-10. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.