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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual Guidance by country: Pakistan: Technical fees

The agreement contains a technical fees article (see INTM153140). These are defined in Article 13(3) as `payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature’.

Pakistan tax may be imposed on such fees `arising in’ Pakistan (Article 13(5)) but must not exceed 12½ per cent of the gross amount.

For the method of calculating the amount of tax credit relief due see INTM168062.