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This convention specifies a dual-rate dividend withholding tax: 5% for companies and government entities, and 10% for all other cases (Article 10). The withholding tax rate for both income from debt-claims (Article 11) and royalties (Article 12) is 10%, with an exemption on debt-claim income for government entities. A building site constitutes a permanent establishment if it lasts over six months (Article 5). The method for eliminating double taxation (Article 23) is primarily exemption, but notably, the deduction method is applied for income from dividends and debt-claims.

CONVENTION BETWEEN the GOVERNMENT of the KINGDOM OF SAUDI ARABIA and the GOVERNMENT of the ISLAMIC REPUBLIC OF PAKISTAN for the AVOIDANCE of DOUBLE TAXATION and the PREVENTION of TAX EVASION with respect to TAXES on INCOME PREAMBLE

The Government of the Kingdom of Saudi Arabia and the Government of the Islamic Republic of Pakistan desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Tax Evasion with Respect to Taxes on Income to promote and strengthen the economic relations between the two countries,

Have agreed as follows:

Contents

CHAPTER I - SCOPE OF THE CONVENTION

Article 1 - Persons Covered

Article 2 - Taxes Covered

CHAPTER II - DEFINITIONS

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

CHAPTER III - TAXATION OF INCOME

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Income from Debt - Claims

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Independent Personal Services

Article 15 - Dependent Personal Services

Article 16 - Directors' Fees

Article 17 - Artistes and Sportspersons

Article 18 - Pensions

Article 19 - Government Service

Article 20 - Students

Article 21 - Teachers & Researchers

Article 22 - Other Income

CHAPTER IV - METHODS FOR ELIMINATION OF DOUBLE TAXATION

Article 23 - Elimination of Double Taxation

Article 24 - Investment Laws

CHAPTER V - SPECIAL PROVISIONS

Article 25 - Mutual Agreement Procedure

Article 26 - Exchange of Information

Article 27 - Members of Diplomatic Missions and Consular Posts

CHAPTER VI - FINAL PROVISIONS

Article 28 - Entry Into Force

Article 29 - Termination

CHAPTER I - SCOPE OF THE CONVENTION

Article 1
Persons Covered

This Convention shall apply to persons who are residents of one or both of the Contracting States.

CHAPTER I - SCOPE OF THE CONVENTION

Article 1Persons Covered

Article 2Taxes Covered

Article 1
Persons Covered

Article 2
Taxes Covered