DoubleTaxationPakistan – France tax treaty: residence, 183 days, rates
Convention entre le Gouvernement de la République française et le Gouvernement de la République islamique du Pakistan en vue d'éviter les doubles impositions et de prévenir l'évasion et la fraude fiscales en matière d'impôts sur le revenu (Paris, 15 June 1994)
- Signed: 15/06/1994
- In force since: 01/09/1996
- Official text
If both countries treat you as resident
- Dual-resident individual: (a) resident of the State where he has a permanent home (foyer d'habitation permanent); if 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 no permanent home in either State — the State where he habitually stays; (c) habitual stay in both or neither — nationality; (d) both nationalities or neither — mutual agreement of the competent authorities. Art. 4(2) Pakistan–France Convention (1994)
- MLI in force for France from 1 January 2019 and for Pakistan from 1 April 2021; effective for taxes other than withholding taxes for tax periods beginning on or after 1 October 2021. MLI articles applied: 6, 7, 8, 9, 12, 13, 15, 16, 17; Art. 4(2), 16 and 24 of the Convention are not modified. Only the authentic texts are legally applicable. impots.gouv.fr — consolidated version of the France–Pakistan Convention as modified by the MLI (unofficial)
- If you have no permanent home in either State, the treaty goes straight to the State where you habitually stay (the centre of vital interests step applies only where there is a home in both States). Art. 4(2)(b) Pakistan–France Convention
- Centre of vital interests: the State with which your personal and economic relations are closer. Art. 4(2)(a) Pakistan–France Convention
- Habitual stay in both States or in neither — the State of which you are a national; both nationalities or neither — the competent authorities settle the question by mutual agreement (Art. 26). Art. 4(2)(c), (d) Pakistan–France Convention
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(1) |
| State pension (social security) | The source country may tax; the country of residence relieves double taxation. | Art. 19(1) |
| 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 10%; 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 | Only the country of residence. | Art. 23(1) |
How double taxation is relieved
- France: 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, director’s fees, performance income, pension) 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.