DoubleTaxationPakistan – Ukraine tax treaty: residence, 183 days, rates
Convention between the Government of Ukraine and the Government of the Islamic Republic of Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Kyiv on 23 December 2008 (with Protocol), as modified by the MLI
- Signed: 23/12/2008
- In force since: 30/06/2011
- Official text
If both countries treat you as resident
- Permanent home; if in both States, the State of 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 where the individual habitually lives; if in both or neither, citizenship; if a citizen of both or neither, the competent authorities decide by mutual agreement. Art. 4(2) Ukraine–Pakistan Convention (2008)
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 only taxes profits of a permanent establishment (fixed base) there. | Art. 7, Art. 14 |
| 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. 18 |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 18 |
| 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. 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 10%; the country of residence relieves double taxation. | Art. 12(2)–(3) |
| 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 |
| Other income | The source country may tax; the country of residence relieves double taxation. | 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), (3)
- Ukraine: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 22(1), (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.