DoubleTaxationPakistan – Czech Republic tax treaty: residence, 183 days, rates
Convention between the Islamic Republic of Pakistan and the Czech Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed on 2 May 2014)
- Signed: 02/05/2014
- In force since: 30/10/2015
- Official text
If both countries treat you as resident
- Dual-resident individual: (a) resident only of the State in which he has a permanent home available to him; if he has one in both States — the State with which his personal and economic relations are closer (centre of vital interests); (b) if that State cannot be determined, or if he has not a permanent home available to him in either State — the State in which he has an habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) national of both or of neither — the competent authorities settle the question by mutual agreement. Art. 4(2) Pakistan–Czech Convention (2014)
- MLI in force for the Czech Republic from 1 September 2020 and for Pakistan from 1 April 2021; it adds the new preamble (Art. 6 MLI), the principal purpose test (Art. 7 MLI) and the mutual agreement procedure rules (Art. 16 MLI). Art. 4, 15 and 22 are unchanged. The authentic texts prevail. Synthesised text of the MLI and the Pakistan–Czech Convention (FBR)
- The Convention was signed on 2 May 2014; under its Art. 28 it entered into force on the exchange of instruments of ratification on 30 October 2015. It has effect in Pakistan for withholding taxes on amounts paid or credited, and for other taxes for taxable years beginning, on or after 1 July following entry into force; in the Czech Republic from 1 January of the calendar year following entry into force. FBR S.R.O. 1322(I)/2015 of 21 December 2015 (notification of the Pakistan–Czech Convention)
- If you have no permanent home available in either State, the treaty goes straight to habitual abode (the centre of vital interests step applies only where there is a home in both States). Art. 4(2)(b) Pakistan–Czech Convention (2014)
- Centre of vital interests: the State with which your personal and economic relations are closer. Art. 4(2)(a) Pakistan–Czech Convention (2014)
- Habitual abode in both States or in neither — resident of the State of which you are a national; national of both or of neither — the competent authorities settle the question by mutual agreement. Art. 4(2)(c), (d) Pakistan–Czech Convention (2014)
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 any 12-month period; the employer is not resident there; the pay is not borne by its permanent establishment there. | Art. 15(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 any 12-month period. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 18 |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| 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 10%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 11(2)-(4) |
| 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. 12(2), (3)(b) |
| 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. 13 |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 21 |
How double taxation is relieved
- Czech Republic: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(2)
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(1)
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.