ATIR Ruled Rental Income and Capital Gains of Resident Pakistanis in UAE, UK Not Taxable in Pakistan

ATIR Ruled Rental Income and Capital Gains of Resident Pakistanis in UAE, UK Not Taxable in Pakistan

Tax experts and a recent Appellate Tribunal Inland Revenue (ATIR) decision provide clarity on the tax treatment of rental income and capital gains earned by resident Pakistanis in the United Arab Emirates (UAE) and the United Kingdom (UK).

Key Takeaway:

Under the tax treaties between Pakistan, UAE, and UK, rental income and capital gains derived from these countries by resident Pakistanis are not taxable in Pakistan.

Background:

A Pakistani resident included exempt foreign income from rental income, capital gains, and bank profits in their tax return. However, the assessing officer challenged this, arguing that foreign income is not exempt and only a tax credit for foreign taxes paid would be available.

The Dispute:

The disagreement centered on the interpretation of the relevant tax treaties. The taxpayer argued that the treaties grant exclusive taxing rights for these income sources to the country where the income arises (UAE/UK) and not Pakistan (residence of the taxpayer).

ATIR's Decision:

The ATIR, in a landmark decision, sided with the taxpayer. They emphasized the following points:

  • Treaty Interpretation: The ATIR applied Supreme Court principles of treaty interpretation, focusing on specific treaty articles.
  • Taxing Rights: The treaties grant taxing rights for rental income and capital gains to the country where the property or asset is located (UAE/UK).
  • "May be Taxed" Clause: The ATIR clarified that the phrase "may be taxed" in the treaties refers to situations where the source country (UAE/UK) does not currently levy tax on that income. It does not grant Pakistan taxing rights.

Impact:

This decision provides significant tax relief for resident Pakistanis earning rental income or capital gains in the UAE and UK. Their income from these sources will not be subject to Pakistani tax.

Expert Opinion:

Tax consultant Shahid Jami highlights potential shortcomings in treaty negotiations. He suggests that Pakistani officials should thoroughly consider national interests and potential tax implications before signing tax treaties.

This article was published at Rental Income and Capital Gains form UK UAE Exempt from Pakistani Tax

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