DoubleTaxationPakistan – Japan tax treaty: residence, 183 days, rates
Convention between the Islamic Republic of Pakistan and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (signed at Islamabad on 23 January 2008)
- Signed: 23/01/2008
- In force since: 09/11/2008
- Official text
If both countries treat you as resident
- Dual-resident individual: (a) resident only of the State where 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 no permanent home available in either State — the State of his habitual abode; (c) habitual abode in both or neither — the State of which he is a national; (d) national of both or neither — mutual agreement. Art. 4(2) Pakistan–Japan Convention (2008)
- Convention signed 23 January 2008, in force 9 November 2008. MLI in force for Japan 1 January 2019 and for Pakistan 1 April 2021; applied provisions: MLI Arts. 4(1) (dual-resident entities only), 6, 7, 9(4), 10, 12, 13(2) and (4), 15, 16(1) first sentence, 17(1). Art. 4(2) of the Convention (individuals) is not changed. Ministry of Finance (Japan) — MLI and the Japan–Pakistan Convention
- Authentic Japanese text: entry into force on the thirtieth day after the exchange of diplomatic notes; applies in Japan from 1 January and in Pakistan (taxes not withheld at source) from tax years beginning on or after 1 July of the year after entry into force; the 1959 Convention ceases to have effect. Japanese text of the Pakistan–Japan Convention (MOFA treaty database)
- If the State of the centre of vital interests cannot be determined, or if the individual does not have a permanent home available in either State, he is deemed a resident only of the State in which he has an habitual abode (the centre of vital interests step applies only where there is a home in both States). Art. 4(2)(b) Pakistan–Japan Convention (2008)
- Centre of vital interests: the State with which your personal and economic relations are closer. Art. 4(2) Pakistan–Japan Convention (2008)(a)
- Habitual abode in both States or in neither — resident only of the State of which he is a national; national of both or of neither — the competent authorities settle the question by mutual agreement (Art. 25). Art. 4(2)(c)–(d) Pakistan–Japan Convention (2008)
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. 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 any 12-month period. | 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 10%; the country of residence relieves double taxation. | Art. 10(2)(c) |
| 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 (over 50%) 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. 22(3) |
How double taxation is relieved
- Japan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(1)
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(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.