Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

Pakistan

Recent developments relating to MAP in Pakistan prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• Pakistan did not provide the relevant information.

Other developments relating to MAP

• Pakistan did not provide the relevant information.

Latest Action 14 Peer Review report

The stage 1 Simplified Peer Review report of Pakistan is expected to be published early 2024.

Tax treaty network of Pakistan

• 66 treaties, applicable to 66 jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: in force.

Table 1. State of play of Pakistan's tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
54	No information	No information

Source: OECD

Pakistan's MAP programme

Organisation of competent authority function

• two persons (both of which on other tasks as well)

• contact persons for MAP requests:

  • Mr. Sajidullah Siddiqui, Director General (International Tax Operations)

    FBR House, Constitution Avenue, G-5, Islamabad-44000, Pakistan.

    Tel. No. [phone] Fax No. [phone] [e-mail].

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	RULE 19D: APPLICATION FOR INITIATION OF MUTUAL AGREEMENT PROCEDURE (MAP), 2002	https://www.fbr.gov.pk/m-a-p/132245/132255 (Section “RULE 19F: FORM OF APPLICATION FOR INITIATION OF MAP PROCEEDINGS” to be referred to for form and content of a MAP request, including information requirements)
MAP profile	23 February 2023	https://www.oecd.org/tax/dispute/pakistan-dispute-resolution-profile.pdf

Overview of Pakistan's MAP Statistics for 2022

Please refer to https://www.oecd.org/tax/dispute/map-statistics-pakistan.pdf for details with respect to Pakistan's MAP Statistics.

Cases closed in 2022

No MAP cases were closed by Pakistan in 2022.

Figure 2. Evolution of Pakistan's MAP caseload (2016-22)

Source: OECD

Table 3. Overview of Pakistan’s MAP caseload for 2022

Inventory for year 2022	Opening Inventory 1/1/2022	Cases started	Cases Closed	End Inventory 31/12/2022
Attribution/allocation cases	1	0	0	1
Other cases	2	0	0	2
Total	3	0	0	3

Source: OECD

Table 4. Pakistan’s average time to resolve MAP cases in 2022

Cases resolved in year 2022	Pre-2016 cases		Post-2015 cases		All
	Number of cases	Average time	Number of cases	Average time	Number of cases	Average time
				Start to End
Attribution / Allocation cases	0	N/A	0	N/A	0	N/A
Other cases	0	N/A	0	N/A	0	N/A
All cases	0	N/A	0	N/A	0	N/A

Source: OECD