DoubleTaxationPakistan – Türkiye tax treaty: residence, 183 days, rates
Agreement between the Islamic Republic of Pakistan and the Republic of Turkey for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Islamabad on 14 November 1985)
- Signed: 14/11/1985
- In force since: 08/08/1988
- 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–Türkiye Agreement (1985)
- 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 or determine the Pakistan-source income of non-residents. Income Tax Ordinance, 2001, s. 107(2)
- If the centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, the individual is deemed a resident of the State in which he has an habitual abode. Art. 4(2)(b) Pakistan–Türkiye Agreement (1985)
- If he has an habitual abode in both Contracting States or in neither of them, he is deemed a resident of the Contracting State of which he is a national. Art. 4(2)(c) Pakistan–Türkiye Agreement (1985)
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 calendar 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. 18 |
| Government service | Only the paying country. | Art. 19(1) |
| Government service pension | Only the paying country. | Art. 19(1) |
| 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)(b) |
| 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 10%; the country of residence relieves double taxation. | Art. 12(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: under certain conditions the source country may also tax (see the article). | Art. 13 |
| 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(2)
- Türkiye: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(3)
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.