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Email No: 228-2017

(TO BE PUBLISHED IN THE GAZETTE OF PAKISTAN EXTRAORDINARY PART.I)

GOVERNMENT OF PAKISTAN
REVENUE DIVISION

Islamabad, the February 16, 2017

NOTIFICATION
Income Tax

S.R.O. 145(I)/2017.- WHEREAS the Third Protocol as set out in the Annexure to
this Notification to amend the Agreement between the Government of the Peoples
Republic of China and the Government of the Islamic Republic of Pakistan for the
Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to
Taxes on Income, signed at Islamabad on November 15, 1989, hereinafter referred to
as the Agreement, as well as the Second Protocol to the Agreement, signed at Beijing
on the April 17, 2007,hereinafter referred to as the Second Protocol;

Whereas, in terms of Article 2 of the Third Protocol, the contracting States shall
notify each other through diplomatic channels that the procedures required by its laws
for the entry into force have been complied with. This Third Protocol shall enter into
force on the date of the receipt of the later notification;

NOW, THEREFORE, in exercise of the powers conferred by sub-section (1) of

section 107 of the Income Tax Ordinance, 2001 (XLIX of 2001), the Federal
Government is pleased to direct that the provisions of the Third Protocol, shall have
effect:
O N S
CA TI
L I
For the provisions of Article 1 of the Second
P UBProtocol,
S the Industrial and
Eare
Commercial Bank of China and the Silk A W Road D A T
Fund included as State
Banks, but only for the purpose L P
of interestUincome they derive from loans in
PAK mentioned
Pakistan for the Energy Projects E ST in the China-Pakistan Economic
L A T
Corridor Energy Projects Cooperation Agreement signed at Beijing on the
November 8, 2014.

Pak Law Publications

Office No. 508, 5th Floor, Shadman Mall, Shadman, Lahore.
Phone: 042-35468539 | 042-37423880 | Cell: 0300-8848226
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Email No: 228-2017

Annexure

THE THIRD PROTOCOL TO THE AGREEMENT BETWEEN THE GOVERNMENT OF THE PEOPLES
REPUBLIC OF CHINA AND THE GOVERNMENT OF THE ISLAMIC REPUBLIC OF PAKISTAN FOR
THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH
RESPECT TO TAXES ON INCOME

The Government of the Peoples Republic of China and the Government of the Islamic Republic of
Pakistan:

Desiring to establish a favorable financing environment for the Energy Projects mentioned in the China-
Pakistan Economic Corridor Energy Projects Cooperation Agreement signed at Beijing on November 8,
2014, by concluding a Protocol to amend the Agreement between the Government of the Peoples
Republic of China and the Government of the Islamic Republic of Pakistan for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Islamabad on
November 15, 1989 (hereinafter referred to as the Agreement), as well as the Second Protocol to the
Agreement, signed at Beijing on April 17, 2007 (hereinafter referred to as the Second Protocol),

Have agreed as follows:

Article 1

For the provisions of Article 1 of the Second Protocol, the Industrial and Commercial Bank of China and
the Silk Road Fund are included as State Banks, but only for the purpose of interest income they derive
from loans in Pakistan for the Energy Projects mentioned in the China-Pakistan Economic Corridor
Energy Projects Cooperation Agreement signed at Beijing on November 8, 2014.

Article 2

The Contracting States shall notify each other through diplomatic channels that the procedures required
by its laws for the entry into force of this Third Protocol have been complied with. This Third Protocol shall
enter into force on the date of the receipt of the later notification. O N S
CA TI
L I
P UatBIslamabad
In Witness Whereof the undersigned, being duly authorized representatives
E
of the two Governments,
S th
have signed this Protocol in the Chinese and English languages
A W D A T on December 8 , 2016,
both texts being equally authentic.
K L UP
A
P EST
For the Government of LAT For the Government of
the Peoples Republic of China the Islamic Republic of Pakistan

[C.No.2(14)Int.Taxes/83]

-Sd-
(Rehmat Ullah Khan Wazir)
Additional Secretary/Member (IR- Policy)

Pak Law Publications

Office No. 508, 5th Floor, Shadman Mall, Shadman, Lahore.
Phone: 042-35468539 | 042-37423880 | Cell: 0300-8848226