DoubleTaxationPakistan – Portugal tax treaty: residence, 183 days, rates
Convention between the Portuguese Republic and the Islamic Republic of Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, with Protocol, signed at Lisbon on 23 June 2000 (Resolução da Assembleia da República n.º 66/2003, Diário da República I Série-A n.º 177, 2 August 2003; Aviso n.º 6/2008)
- Signed: 23/06/2000
- In force since: 04/06/2007
- Official text
If both countries treat you as resident
- A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, a resident of the State with which his personal and economic relations are closer (centre of vital interests). Art. 4(2)(a) Pakistan–Portugal Convention (2000)
- Subject to s. 109, a double taxation agreement and its implementing notification have effect notwithstanding anything in any other law, so far as they provide relief from tax under the Ordinance, determine the Pakistan-source income of non-residents, or provide for exchange of information. Income Tax Ordinance, 2001, s. 107(2)
- If the State of the centre of vital interests cannot be determined, or if he has no permanent home available to him in either State, he is deemed to be a resident of the State in which he has an habitual abode. Art. 4(2)(b) Pakistan–Portugal Convention (2000)
- If he has an habitual abode in both States or in neither of them, he is deemed to be a resident of the State of which he is a national (c); if he is a national of both States or of neither of them, the competent authorities settle the question by mutual agreement (d). Art. 4(2)(c), (d) Pakistan–Portugal Convention (2000)
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. 19(1) |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 18(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 18(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)(i) |
| 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)-(3) |
| Royalties (copyright, licences) | Source country: at most 10%; the country of residence relieves double taxation. | Art. 12(2)-(3) |
| Technical, consulting, management services | Source country: at most 10%; the country of residence relieves double taxation. | Art. 12(2), (4)-(5) |
| 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, including shares: only the country of residence. | Art. 13; MLI Art. 9(4) |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 22(3) |
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. 23(3)
- Portugal: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(2), (4)
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.