DoubleTaxationPakistan – Germany tax treaty: residence, 183 days, rates
Agreement between the Federal Republic of Germany and the Islamic Republic of Pakistan for the avoidance of double taxation with respect to taxes on income, signed at Islamabad on 14 July 1994 (with Protocol; BGBl. 1995 II S. 836)
- Signed: 14/07/1994
- In force since: 30/12/1995
- Official text
If both countries treat you as resident
- A person resident in both States is deemed resident of the State where he has a permanent home available; if in both, where his personal and economic relations are closer (centre of vital interests). If that cannot be determined, or if he has no permanent home available in either State, the State of his habitual abode; then nationality; if a national of both or neither, the competent authorities settle the question by mutual agreement. Art. 4(2) Pakistan–Germany Agreement (1994)
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. 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 120 days in the tax year. | Art. 7, Art. 14 |
| Pension | The source country may tax; the country of residence relieves double taxation. | Art. 18 |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1) |
| 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 20%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 11(2)(b) |
| 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), (4) |
| 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 | Only the country of residence. | Art. 21(1) |
How double taxation is relieved
- Germany: 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) Art. 22(1)
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(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.