ISLAMABAD: Appellate Tribunal Inland Revenue (ATIR) Islamabad has declared that there is no bar under international law for the state of residence (Pakistan) to impose a tax on income from property situated in another country (UAE).
According to a judgement of the tribunal issued on November 14, 2022, the tribunal is of the considered opinion that there is no bar under the state of residence to impose a tax on income from property situated in another state.
The tribunal has rejected the appeal of a Pakistani taxpayer for not taxing the foreign source immovable property income from the UAE. Details of the case revealed that the appellant taxpayer is an individual who derives income from salary and foreign source immovable property income. The case was selected for audit under section 214D of the Income Tax Ordinance, and intimation in this regard was issued by the concerned Commissioner. Thereafter, an Information Document request under section 177(1) of the Ordinance was issued to the taxpayer through IRIS.
Subsequently, the case of the appellant was transferred to the AEOI Zone, Islamabad. Information Document Request was once again issued to the appellant, wherein, the appellant was requested to furnish various details, documents, and other related information about the declaration made in the income tax return filed by the appellant for the Tax Year 2017. The appellant filed a reply along with certain documentation on December 25, 2020.
