DoubleTaxationPakistan – Poland tax treaty: residence, 183 days, rates
Convention between the Islamic Republic of Pakistan and the Polish People's Republic for the avoidance of double taxation of income (signed at Warsaw on 25 October 1974)
- Signed: 25/10/1974
- In force since: 24/11/1975
- Official text
If both countries treat you as resident
- Dual-resident individual: (a) resident 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 closest (centre of vital interest); (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) if residence cannot be determined under (a) and (b), the competent authorities settle the question by mutual agreement. There is no nationality step. Art. 4(2) Pakistan–Poland Convention (1974)
- Prepared jointly by the competent authorities. MLI in force for Poland from 1 July 2018 and for Pakistan from 1 April 2021; MLI Arts. 4(1), 5(6), 6(1), 7(1), 8(1), 9(4), 11(1) and 17(1) apply — for Poland for withholding taxes from 1 January 2022 and for other taxes for taxable periods beginning on or after 1 October 2021. Art. 5(6) MLI (Option C) replaces the exemption method of Art. 22(1) with the credit method for residents of both States; Art. 4(2) and Art. 15 are unchanged. Not a source of law; the authentic texts prevail. Synthesised text of the MLI and the Pakistan–Poland Convention (FBR)
- Signed 25 October 1974, in force 24 November 1975 (treaty-database header of the FBR copy); effective in Pakistan for income arising on or after 1 July 1973 and in Poland on or after 1 January 1973 (Art. 27(2)). Pakistan–Poland Convention (1974), FBR copy header; Art. 27
- 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–Poland Convention (1974)
- Centre of vital interests: the State with which your personal and economic relations are closer. Art. 4(2)(a) Pakistan–Poland Convention (1974)
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 183 days in the tax year. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 21 (no private pensions article) |
| Government service | Only the paying country. | Art. 18(1) |
| Government service pension | Only the paying country. | Art. 18(1) |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6(1), (3) |
| Dividends | The source country may tax; the country of residence relieves double taxation. | Art. 10 |
| Interest (deposits, bonds, loans) | Only the source country (for pensions, the paying country). | Art. 11(1) |
| Royalties (copyright, licences) | Only the source country (for pensions, the paying country). Other rates or exemptions apply in some cases (see the article). | Art. 12(1) |
| 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. 6(3); Art. 13; MLI Art. 9(4) |
| Other income | Only the country of residence. | Art. 21(1) |
How double taxation is relieved
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(1) replaced by MLI Art. 5(6) (Option C); Art. 22(2)
- Poland: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(1) replaced by MLI Art. 5(6) (Option C); 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.