Article 1 - Taxes covered - Pakistan

MINISTRY OF FINANCE (Department of Revenue) (Foreign Tax Division) NOTIFICATION New Delhi, the 29th August, 1989 INCOME-TAX G.S.R. No. 792(E). Whereas the annexed Agreement between the Republic of India and the Islamic Republic of Pakistan for the avoidance of double taxation of income derived from international air transport has entered into force on the 1st day of August, 1989, on the notification by both the Contracting States to each other of completion of the procedures required by their respective laws, as required by article 5 of the said Agreement. Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), and section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1964), the Central Government hereby directs that all the provisions of the said Agreement shall be given effect to in the Union of India. ANNEXURE AGREEMENT BETWEEN THE REPUBLIC OF INDIA AND THE ISLAMIC REPUBLIC OF PAKISTAN FOR THE AVOIDANCE OF DOUBLE TAXATION OF INCOME DERIVED FROM INTERNATIONAL AIR TRANSPORT The Government of the Republic of India and the Government of the Islamic Republic of Pakistan. Desiring to conclude an agreement for the avoidance of double taxation of income derived from international air transport: Have agreed as follows: Article 1 TAXES COVERED 1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political sub-divisions or local authorities irrespective of the manner in which they are levied. 2. The existing taxes to which this Agreement shall apply are: (a) in the case of Pakistan: (i) the income-tax; (ii) the super tax; and (iii) the surcharge; (hereinafter referred to as Pakistan tax ); (b) in the case of India: (i) the income-tax including surcharge thereon; and (ii) the surtax; (hereinafter referred to as Indian tax ). 3. This Agreement shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Agreement in addition to, or in place of, the taxes referred to in paragraph 2 of this article. The competent authority of a Contracting State shall, as soon as possible or at least at the end of each year, notify the other of any substantive changes which are made in its taxation law.