DoubleTaxationPakistan – Switzerland tax treaty: residence, 183 days, rates
Agreement between the Swiss Confederation and the Islamic Republic of Pakistan for the avoidance of double taxation with respect to taxes on income, signed at Islamabad on 21 March 2017 (with Protocol; SR 0.672.962.31)
- Signed: 21/03/2017
- In force since: 29/11/2018
- Official text
If both countries treat you as resident
- Deemed resident only of the State where the person has a permanent home; if in both, the State with closer personal and economic relations (centre of vital interests). If that cannot be determined, or there is no permanent home in either State, the State of habitual abode; if habitual abode in both or neither, nationality; if a national of both or neither, mutual agreement of the competent authorities. Art. 4(2) Pakistan–Switzerland Agreement (2017)
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. 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 the tax year. | 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 20%; the country of residence relieves double taxation. | Art. 10(2)(b) |
| 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 7%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 13(2)–(3); Protocol para. 4 |
| 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. 14 |
| Other income | The source country may tax; the country of residence relieves double taxation. | No other-income article |
How double taxation is relieved
- Switzerland: exemption: the income is not taxed but counts towards the rate on other income (credit for dividends, interest, royalties, fees for technical services) Art. 22(2)
- Pakistan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(1)
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.