DoubleTaxationPakistan – Austria tax treaty: residence, 183 days, rates
Convention between the Republic of Austria and the Islamic Republic of Pakistan for the avoidance of double taxation with respect to taxes on income, signed at Islamabad on 4 August 2005 (BGBl. III No. 49/2007), as modified by the MLI
- Signed: 04/08/2005
- In force since: 01/06/2007
- Official text
If both countries treat you as resident
- Permanent home; if in both States, centre of vital interests; if that cannot be determined, or there is no permanent home in either State, habitual abode; if habitual abode in both or neither, nationality; if a national of both or neither, the competent authorities endeavour to settle the question by mutual agreement. The MLI does not modify Art. 4. BMF — Synthesised text of the MLI and the Austria–Pakistan Convention (signed 4 August 2005), prepared jointly by the competent authorities: Art. 4(2), Art. 16(2), Art. 20, Art. 24 (para. 1(a) as modified by Art. 5(2) MLI, Option A; Austria from 1 January 2022)
- If the centre of vital interests cannot be determined, or if the person has no permanent home available in either State, he or she is deemed resident of the State of habitual abode. Art. 4(2) Austria–Pakistan Convention (2005) (MLI synthesised text)
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; the pay is not borne by its permanent establishment there. | Art. 16(2) |
| 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. 7, Art. 15 |
| Pension | Only the country of residence. | Art. 19 |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 20 |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 20 |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6(1) |
| Dividends | Source country: at most 15%; the country of residence relieves double taxation. | Art. 10(2)(b) |
| Interest (deposits, bonds, loans) | Source country: at most 15%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 11(2) |
| Royalties (copyright, licences) | Source country: at most 10%; the country of residence relieves double taxation. | Art. 12(2) |
| Technical, consulting, management services | Source country: at most 10%; the country of residence relieves double taxation. | Art. 13(2)–(3) |
| 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). | Art. 14 |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 23(3) |
How double taxation is relieved
- Austria: exemption: the income is not taxed but counts towards the rate on other income (credit for dividends, interest, royalties, fees for technical services, gains on sale, other income) Art. 24(1)
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(2)
Data checked: 10/11/2026. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.