Article 1
Personal Scope
This Convention shall apply to persons who are residents of one or both of the Contracting States.
Website Last updated:
June 26, 2026
The Government of the United Arab Emirates and the Government of the Islamic Republic of Pakistan,
Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Have agreed as follows:
Contents
Article 1 - Personal Scope
Article 2 - Taxes Covered
Article 3 - General Definitions
Article 4 - Resident
Article 5 - Permanent Establishment
Article 6 - Income From Immovable Property
Article 7 - Business Profits
Article 8 - Air and Shipping Transport
Article 9 - Associated Enterprises
Article 10 - Dividends
Article 11 - Interest
Article 12 - Royalties
Article 13 - Technical Fees
Article 14 - Capital Gains
Article 15 - Independent Personal Services
Article 16 - Dependent Personal Services
Article 17 - Directors' Fees
Article 18 - Entertainers and Athletes
Article 19 - Government Service
Article 20 - Pensions and Annuities
Article 21 - Students and Apprentices
Article 22 - Professors and Teachers
Article 23 - Other Income
Article 24 - Methods for the Elimination of Double Taxation
Article 25 - Non-discrimination
Article 26 - Mutual Agreement Procedure
Article 27 - Exchange of Information
Article 28 - Diplomatic and Consular Activities
Article 29 - Entry Into Force
Article 30 - Termination
This Convention shall apply to persons who are residents of one or both of the Contracting States.
The taxes to which the Convention shall apply are:
In the United Arab Emirates:
income tax.
corporation tax.
surcharge on services.
(hereinafter referred to as the 'United Arab Emirates tax').
In Pakistan:
the income tax;
the super tax; and
the surcharge.
(hereinafter referred to as 'Pakistan tax').
The Convention shall also apply to any identical or substantially similar taxes which are imposed by either Contracting States after the date of signature of the present Convention in addition to, or in place of, the taxes referred to in paragraph 1. The competent authorities of the Contracting States shall notify each other of any substantial changes which are made in their respective taxation laws.