A delegation of HMRC including the Security expert of HMRC visited FBR (HQ) Islamabad from 17th to 20th July, 2017 to assist in implementation of AEOI Standard. An OECD/ HMRC team comprising of mr. Donal Godfrey, Mr. Lloyd Garrichinho, and Mr. Jon Swerdlow visited Karachi for facilitation and education of the financial industry from 7th to 9th May, 2017. A team of OECD/ HMRC visited FBR(HQ) Islmabad from 16th- 18th January, 2017 to assist in implementing the Standard on AEOI and for orientation of the Financial sector. Seminar on AEOI Pilot Project for Non-Banking Sector Conducted at SECP Islamabad on 30th Dec, 2016. Seminar on AEOI Pilot Project for Banking Sector Conducted at SBP Karachi on 16 Nov,2016. Mr. Jon Swerdlow of HMRC visited FBR (HQ) Islamabad from 5th to 8th December, 2016. AEOI Pilot Project Approved by The Minister for Finance and Revenue, Pakistan, Mr. Mohammad Ishaq Dar and Pilot Project Team Notified.

ARTICLE 26 EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Articles 1 and 2.

2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. Notwithstanding the foregoing, information received by a Contracting State may be used for other purposes when such information may be used for such other purposes under the laws of both States and the competent authority of the supplying State authorises such use.

3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:

  1. to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
  2. to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
  3. to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public).

4. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.

5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person


Member (IR Policy)
Dr. Muhammad Iqbal
Chief (International Taxes)
Mr. Mohammad Iqbal
Secretary (EOI)
Ms. Rabia Yaseer Durrani