Double Taxation Agreement

ARTICLE 1: PERSONAL SCOPE ARTICLE 2: TAXES COVERED
16.	Scope.
16.1	Relation between tax object and the person receiving income and the State.
17.	Tax.
17.1.	Scheme of Income-tax Ordinance is to create charge, define, classify and quantity income.
17.2	Incomposition of tax.
17.3	Income-tax Ordinance governs taxation of income in the absence of provision in agreement.
18.	Income.
18.1	To constitute income source is necessary.
18.2	Nature of receipts decided at the time it is received.
18.3.	Nomenclature of receipt is not decisive.
18.4.	Whether a receipt is capital or revenue.
18.5	Compensation on termination of agency itself vis-a-vis compensation on termination of agreement which is not the source of income.
18.6	Amount paid for refraining form carrying on competitive business.
18.7	Compensation for surrender of industrial licence.
18.8	Amount received on termination of agreement for distribution of films.
18.9	Forfeiture of security deposited by lessee.
18.10	Compensation on termination of contracts is capital receipt except in certain cases.
19.	Total income- Meaning of.
20.	Total income - Scope of.
21.	Total income - Computation of.
22.	Total income - Assessability of.
22.1	Receipt of income.
22.1-1	Constructive receipt of income is not the same thing as actual receipt.
22.1-2	Settlement of account means receipt of income.
22.1-3	Income received does not mean income receivable.
22.1-4	Income is received when recipient gets money under his control.
22.1-5	Receipts through book entries.
22.1-6	Deemed receipt.
22.1-7	Receipt through cheque - Place of receipt.
22.1-8	Receipt v accrual or arising of income.
22.2	Accrual or arising of income.
22.2-1	Accrual means right to receive.
22.2-2	Income has not resulted if there is neither accrual nor receipt.
22.2-3	When income accrues or arises, receipt is not relevant.
22.3	Concept of deemed accrual.
22.3-1	Deemed accrual and business connection.