Double Taxation Agreement

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HISTORICAL PERSPECTIVE

1.	International tax treaties.
2.	Double taxation agreements.
2.1.	Objectives.
2.2.	Pattern of taxation.
3.	Development of double taxation agreement models.
3.1	Andean Model and OECD Model.
3.2	UN Model and OECD Model.
3.3.	US Model and OECD Model.
3.4.	Agreement between developed and developing countries.
3.5.	Treaty models lead to development of international tax law.
3.6	Model Convention of OECD.
4.	Scope of double taxation agreements.
5.	Policy of Government vis-a-vis double taxation agreement.
6.	Double taxation agreements vis-a-vis Income-tax Ordinance, 1979.
7.	Double taxation agreements whether decide or allocate jurisdiction.
7.1	Residence.
7.2	Source.
7.3	Permanent establishment.
8.	Unilateral relief vis-a-vis bilateral relief.
8.1	Unilateral relief.
8.1-1	Exemption of foreign source income.
8.1-2	Foreign tax credit system.
8.1-3	Section 164 and unilateral relief.
9.	Such doubly taxed income - Meaning of.
10.	Foreign collaboration policy in Pakistan.
10.1	Technology, meaning of.
10.2	Technology policy in Pakistan.
10.3	Role of double taxation agreements.