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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Double Taxation Relief Manual Guidance by country: Pakistan: Dividends

Relief for Pakistan underlying tax is available only if the United Kingdom recipient of the dividend is a company controlling, directly or indirectly, 10 per cent of the voting power of the Pakistan company.

Pakistan direct tax on the dividend is restricted as follows

  • where the recipient is an individual: 20 per cent
  • where the recipient is a company controlling more than 50 per cent of the voting power of the payer and the payer carried on an `industrial undertaking’ when the agreement came into force: 10 per cent.
  • Where the industrial undertaking was set up later the control requirement is reduced to 25 per cent of the voting power. `Industrial undertaking’ is defined in Article 10(4)(b).
  • where the recipient is a company other than those referred to above: 15 per cent.