DoubleTaxationPakistan – Romania tax treaty: residence, 183 days, rates
Convention between the Government of the Islamic Republic of Pakistan and the Government of Romania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income — signed at Bucharest on 27 July 1999
- Signed: 27/07/1999
- In force since: 13/01/2001
- Official text
If both countries treat you as resident
- 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, resident of the State with which his personal and economic relations are closer (centre of vital interests). Art. 4(2)(a) Pakistan–Romania Convention (1999)
- 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 in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he is deemed a resident of the State in which he has an habitual abode. Art. 4(2)(b) Pakistan–Romania Convention (1999)
- Habitual abode in both States or in neither — resident of the State of which he is a national; national of both States or of neither — the competent authorities settle the question by mutual agreement. Art. 4(2)(c)–(d) Pakistan–Romania Convention (1999)
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(1) |
| State pension (social security) | Only the source country (for pensions, the paying country). | Art. 19(1) |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 20(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 20(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 10%; the country of residence relieves double taxation. | Art. 10(2) |
| Interest (deposits, bonds, loans) | Source country: at most 10%; the country of residence relieves double taxation. | Art. 11(2) |
| Royalties (copyright, licences) | Source country: at most 12.5%; the country of residence relieves double taxation. | Art. 13(2) |
| 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, including shares: only the country of residence. | Art. 14 |
| Other income | Only the country of residence. | Art. 23(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. 24
- Romania: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24
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.