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Sindh High Court 2021 Customs Act of 1969

2021 PTD 885

Double taxation
THE COMMISSIONER INLAND REVENUE, ZONE-IV, CORPORATE REGIONAL TAX OFFICE, KARACHI AND OTHERS
Appellant
VS
MESSRS MSC SWITZERLAND GENEVA AND OTHERS
Respondent

Case Laws / Head Notes / Paras

International Treaties---Super tax, levy of---Question was with regard to exemption of taxpayer from Super tax on the plea that they were otherwise qualified and fell within Double Taxation Treaties between Pakistan and foreign countries---Validity---Super tax as levied was prima facie identical / substantially similar to existing levies expounded in Treaty, therefore, case of tax payers was clinched per Art.2(3) of the Treaty---Super tax was a tax on income and such levy was identical / substantially similar to levies existing at the time that the Treaty was entered into--- Tax payers who were otherwise qualified and fell within double taxation treaties between Pakistan and respective foreign countries were either exempt or wherever applicable were liable to pay super tax at reduced rates...