ZAFAR & ASSOCIATES - LLP | International Tax Law - Pakistan
International tax law is applicable to the taxing of activity that takes place in two or more countries in form of international tax agreements between two or more countries, are also known as income tax treaties, or tax conventions or double taxation agreements or DTAs.
International tax law also exists in domestic tax laws that consider the jurisdiction to tax entities, and that concern the taxation on foreign income of residents, domestic income of non-residents and cross-border transactions.
A global business can become entangled in a complex web of tax rules and regulations in unfamiliar territories. We can help align your tax strategies with your business needs, meeting compliance obligations wherever they arise. Similarly, governments and tax authorities around the world are responding to globalization, economic uncertainty and the connected economy by imposing tighter trading rules and pursuing tax revenues with ever more determination.
Multinational organizations now face more and more demands from different jurisdictions as individual authorities endeavor to collect taxes on cross-border activities. At ZA-LLP, we believe that dedicated international tax professionals are best equipped to tackle these demands, as well as uncover planning opportunities that can lead to enhanced financial performance.
Broad Capabilities
Our professionals focus on the critical field of transfer pricing, providing services ranging from comprehensive supply chain restructuring to transfer pricing planning to controversy management to aiding in compliance with documentation requirements.
Foreign Tax Desks
The ZA-LLP foreign tax desk programme has revolutionized the provision of international tax services. Professionals serving on desks work side-by-side with colleagues on similar rotations, creating a dynamic, team-based environment that fosters the development of truly integrated planning solutions - whenever and wherever they are needed.
Scope of Practice
ZA-LLP's tax practice group, under the aegis of Sr. Partner, Dr. Zafar, advises clients in virtually all areas of domestic and international taxation, including income taxation, corporate taxation, real estate taxation, intellectual property taxation and value-added tax. We specialize in developing creative solutions to complex problems inherent in structuring cross-border commercial, investment and technology transfer transactions, making full use of the global network of double-taxation treaties and off-shore tax solutions. We have assisted both domestic and foreign multinationals in resolving sensitive tax-related issues both in Pakistan and around the globe. We have developed a network of international taxation experts around the globe with whom the tax practice group regularly consults regarding foreign tax ramifications on cross-border deals. Representation also extends to tax and other investment incentives under national, regional and multilateral regimes. ZA-LLP’s representation extends to all relevant tax authorities as well as to both civil and white-collar litigation in the courts.
Lawyers in the Firm’s International Tax group routinely advise clients with respect to the extraterritorial aspects of Pakistan income taxation, both in connection with the Firm’s transactional work for business and individual clients, and as special tax counsel to smaller law firms with an international business practice and in other situations. We advise clients on the Pakistan tax consequences of numerous cross-border transactions and assist in structuring inbound and outbound business and financial relationships.
Evolution of Tax Culture
Let's take a look at the insight as given by Dr. Zafar, Senior Partner on Evolution of Tax Culture for the Revival of Economy "The very issue of tax and its administration vis-à-vis economy is not only the concern of this gathering or that of our country alone falling in the category of developing countries, this is very much crucial and highly debatable topic even in the United States and other developed countries of this globe." Paper read during National Tax Conference at Karachi on Feb. 21-22, 2003.
The following are among the areas where members of the International Tax group have advised foreign and domestic clients:
Investments in hybrid and specialized foreign and domestic securities
Cross-border joint ventures and global strategic alliances
Asset purchase and sale transactions within and outside Pakistan
Cross-border licensing
Pakistan and foreign branch operations
Pakistan and foreign purchasing transactions
Cross-border equipment leasing transactions
Investments in foreign and domestic real estate
Domestic and foreign project finance transactions
Transactions involving emerging markets including former Soviet Bloc countries
Cross-border transfers of employees
Tax aspects of international philanthropy
Cross-border aspects of e-commerce and transfers of intangibles
Members of the International Tax group also work closely with the client’s other advisors, including in-house counsel and accountants, public accountants and investment bankers. Our lawyers also have established good working relationships with tax professionals in many foreign countries, including law firms, accounting firms and tax consulting firms and work with such foreign professionals as needs dictate.
Agreements as to Avoidance of Double Taxation
The Government of Pakistan has so far signed agreements to avoid double taxation with 64 countries including almost all the developed countries of the world. These agreements lay down the ceilings on tax rates applicable to different types of income arising in Pakistan. They also lay down some basic principles of taxation which cannot be modified unilaterally. The list of countries with which Pakistan has concluded tax treaties is given below:
Members of the International Tax group have assisted clients in connection with controversies involving international tax issues before the Central Board of Revenue. Working with members of the Firm’s Individual Clients Department, lawyers in the International Tax group regularly assist in estate, family and business planning structures for expatriates, nonresident aliens and Pakistani citizens with foreign family and business interests.
Our tax lawyers are well conversant that how the multinationals' international transactions are taxed in Pakistan. They deal with the matters of banking sector, non-resident companies, petroleum / gas exploration companies, pharmaceuticals, telecommunication, satellite TV channels and mobile phone companies. Our legal experts are capable to examine international transactions of permanent establishments with particular reference to e-commerce, e-communications, electronics / computer softwares, splitting of contracts and determination of beneficial ownership and attribution concepts of investment income. The Federal Board of Revenue (FBR) of Pakistan is going to reform International Tax Rules and our advisors are keenly watching the changes to be made so that all the effectees may not suffer more than their due share. Although the complexity and inconsistency of the International Tax Law in Pakistan annoy the executives of multinational companies but our tax lawyers have the expertise to soothe their displeasure.
Our Core Competencies
1
Collaborative Skillset
Collaborative lawyers trust the wisdom of the group; lone wolves and isolationists do not do any good anymore.
2
Emotional Intelligence
Distant, detached lawyers are relics of the 20th century, the market no longer wants a lawyer who is only half a person.
3
Technological Affinity
If you can not effectively and efficiently use e-communications, and mobile tech, you might as well just stay home.
4
Time Management
Virtually a substantial part of lawyers difficulties in this regard lie with their inability to prioritise their time.
What People Say About Us
Thank you for your email and the final draft. Indeed it is one of the finest drafts I have come across with. Certainly, your commitment level, eagerness to resolve, intellectual strength, attention to detail and legal expertise are commendable. Under your admirable guidance and direction, I have been able to maneuver with immense success and will reach fruition much earlier than anticipated. Thank you for being so supportive!
Yaser Shan ~ Toronto, Canada
Thank you again so much for this wonderful service. I just wanted you both to know, I spent weeks searching for a service in Pakistan like this, that could legally handle payroll for a Pakistani employee for a US based business and so far I am extremely happy with your organization's service and punctuality. Your service thus far is absolutely amazing and I know Sunita is grateful that we were able to find your organization to ensure her position at our company.
Prince E. Rich IV | CEO ~ Rich Technology Group LLC, USA
We are very happy with the work you have done. Its highly appreciated the professionalism and deep research by the team. Accept our deep gratitude! I do not know how to say Thank you to you and your team! It's a masterpiece you have created and we are very thankful for your help to assist in our social cause.
Imtiaz Makhani ~ Karachi, Pakistan
Thank you very much for your fantastic support, which has been absolutely invaluable throughout the process. We really enjoyed working with you and look forward to plenty more opportunities for shared projects into the future.
Dr. Albrecht Muser | KPMG ~ München, Germany
Working with all of you over the last years has been a pleasure and an honour! Your expertise, focus on customer service and professionalism make it possible for us to provide superior services to our clients and I am so grateful to you.
Maude Burger-Smith ~ Cape Town, South Africa
We are glad to inform you the receipt of current outstanding balance in our bank account from the disputed party. Therefore we request you to arrange to close the dispute case with them as per our management decision. We would like to take this opportunity to thank you for all the support and advice to solve this matter. It was pleasure working with you all.
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Thank you for your support in this process and for your great hospitality. Your assistance has been of great importance. It was also important to see and experience the high quality of your services and your well known firm.
Magnus Greko ~ Sweden
Thank you for your support in this process. Your assistance has been invaluable. We are looking forward to a long lasting working relationship with you. Also, thank you for hospitality during these past days.
Lothar Geilen ~ Germany
Dear Atty. Iram Fatima: I would like to let you know that my wife came in USA last week. The U.S. Embassy Islamabad approved her visa petition in the lights of all the wonderful endeavors done by you and Mr. Birach. It was a long legal battle of about 7 years. I must say that your law firm is one of the best in the country and you are a highly professional advocate. Dr. Zafar should feel proud to have you in his crew. Finally, again I would say Thanks for all your legal services and I am your best reference.
Zubair Mufti ~ Texas, USA
Dear Dr Zafar and Iram: Thank you very much for timely submission of the excellent opinion letter. It is very well drafted and covers the key points. We very much appreciate your excellent and timely work in preparing the legal opinion.
Mrs. Iqbal Farrukh ~ San Francisco, USA
Dear Attorney Iram Fatima: Thanks so much for all of your kind efforts in this area and I must admit that your legal firm is the best in the country.
Zubair Mufti ~ Texas, USA
The efficiency and effectiveness of your services are much appreciated.
James Alexander Linton Williams ~ UK
We are complately satisfied with the e-communication and provided services. We would like to thank the whole team, and Ms Iram Fatima in particular, for your professionalism and the Due Diligence you carried out.
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Many thanks for this, and thank you for being so prompt. It is very appreciated.
Alex Gilchrist ~ Somerset, UK
Thank you again for handling my case so well, I am honoured to be represented by you.
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Thank you very much for your great attention to my case, I see that you're a very serious company and I'm happy that I've choose you.
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I really appreciate the help and support provided by Zafar and Associates to our company. I don’t know what to say or how to thank you, but to tell the truth your services are really the best legal services we have ever received. You are truly a professional and effective law firm.
Adnan Branbo ~ Dubai, UAE
Thank you very much for your contribution. We will review the information and incorporate it into the International Citation Manual of Washington University Global Studies Law Review. Your help is appreciated.
Naomi Levin ~ Washington, USA
I wanted to let you know that i got the documents. And i wanted to thank you and the whole team who worked on my case. You all did a good job thanks again.
Naima Ashraf ~ The Hague, Holland
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Susan Bauer ~ London, UK
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I must say your handling of this matter has been totally sterling and I shall not have any hesitation in recommending you and your firm to others.
Rosina Ahmad ~ UK
Good morning, I received the documents back yesterday afternoon. Thank you so much for your quick response to the job. We really appreciate it. Looking forward to working with you in the further.
Mrs. Jan Malcolm ~ Auckland, New Zealand
Thank you very much for the case. It is just brilliant! I am so grateful that you went out of your way to help me.”
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I do appreciate highly the sense of commitment your office wishes to dedicate to the follow up of our question for information. I have transmitted the contents of your email IMMEDIATELY to the contact, together with confirmation of the highest esteem we attribute to the quality of the services rendered by ZAFAR & ASSOCIATES.
Paul Wouters ~ Istanbul, Turkey
Thank you very much for the information and good news. I know you’ve been working too hard and I appreciate every single minute working with you all. It’s an experience to be in the team of hardworking people and I am very proud to be included.
Evangeline Williams ~ Paphos, Cyprus
I would like to thank you for your swift and excellent service that your office recently provided us. I would definitely forward your contact information to my friends and family in reference to seeking legal matters in Pakistan. I would also inform Sean Hogan and his associates to pass on your contact information to any clients that may need assistance in the matters of law in Pakistan.
Zarar Khan ~ Miami, USA
We are greatly impressed with your firm and the professional calibre of the partners. If acceptable, we would like to keep your firm as a reference for future projects. Please let me know.
Tanaz Pardiwala ~ Barcelona, Spain
We are happy to inform you that we have received the original succession certificate via DHL. I want to take this opportunity to thank you for your efforts, especially Dr. Zafar, who was kind enough to handle the security deposit at the court. With our best wishes and success for the New Year, to you and your esteemed team, we remain with.
Mansur Asrar ~ Istanbul, Turkey
I am writing to convey to you how much I appreciate your prompt service! My mother called me today and informed me that 2 lawyers from your firm visited her. It is a pleasant surprise to know that such a law firm exists in our very own country. I would definitely recommend your firm to any friend who is in need of professional legal services in Pakistan.
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I am truly very impressed with the follow up of your law firm. I never thought a Pakistani firm would be so aggressive and pro-active. Do you even happen to come to NYC? If so, then please look me up here when you visit next.
Faisal Mumtaz ~ New York, USA
I want to thank you for all services you have rendered to us. I really appreciate it and hope on further cooperation.
Petrov Andrey ~ Moscow, Russia
With God's help you have done a great thing for our family. Thank you so much for your diligence and expertise. We are truly grateful to God for all that is possible now. We also are looking forward to meeting you and your staff when we arrive in Pakistan next month. Please let us know if there is anything we can bring for you from the United States as a gift.
Shaukat Minhas and Colleen Davidson ~ Dallas, USA
Your help in investigation case is well appreciated. My brother and I are ever grateful to you for obtaining the document. Thank you and god bless you and your practice team.
Kevin Lessani - Dallas - USA
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M. Iftikhar Sheikh ~ Dhahran, Kingdom of Saudi Arabia
