New Income Tax Rule 19A outlines the application process, required documents and deadlines for Pakistani residents seeking tax relief under double taxation agreements with foreign countries.
ISLAMABAD: The Federal Board of Revenue (FBR) has prescribed a procedure for issuing certificates of residence to Pakistani taxpayers seeking tax relief under agreements for the avoidance of double taxation and fiscal evasion during Tax Year 2027.
The FBR has issued the Income Tax Rules, 2002, updated up to September 15, 2026, for Tax Year 2027, covering the period from July 1, 2026, to June 30, 2027.
Under Rule 19A, a person resident in Pakistan can apply to the competent authority for a certificate of residence for submission to the tax authorities of another country with which Pakistan has signed a double taxation agreement.
The certificate may help eligible taxpayers obtain reduced tax rates, tax credits, tax sparing credits or other fiscal relief in the foreign country.
Application Requirements
Applicants must submit an application to the Competent Authority of Pakistan at the Federal Board of Revenue, Constitution Avenue, Islamabad.
The prescribed application form requires the following information:
• Applicant’s name and legal status (individual, association of persons or company).
• CNIC, registration or incorporation number.
• Pakistani address and contact details.
• National Tax Number (NTN).
• Income declared for the relevant tax year.
• Name and designation of the foreign tax authority.
• Details of income earned and the country where it was received.
Applicants must also provide supporting documents, including proof of foreign income, CNIC, NTN certificate, certificate of incorporation where applicable, and the latest income tax return, where applicable.
FBR Sets 45-Day Issuance Deadline
Under Rule 19A, the competent authority may request a verification report from the relevant Commissioner of Inland Revenue.
The Commissioner must submit the report within 30 days of receiving the request from the FBR.
After receiving the necessary information, the competent authority must decide on the application and issue the certificate of residence within 45 days of submission.
The certificate will contain details of the taxpayer’s identity, residence, income sources, declared or assessed income and total tax paid or payable in Pakistan.
Separate Application Required Every Year
The FBR has clarified that taxpayers must submit a separate application for each tax year, and a separate certificate will be issued for every year.
If the competent authority refuses an application, it must communicate the rejection and provide reasons within 45 days of receiving the application.
The new procedure provides a formal mechanism for Pakistani residents seeking to benefit from the country’s double taxation agreements while establishing their tax residency status before foreign tax authorities.