Case Information
- Court: Supreme Court of Pakistan
- Case No: Civil Review Petitions No. 988–1001/2023
- Applicant: Interquest Informatics Services
- Defendant: The Commissioner of Income Tax
- Judgment Date: 28 November 2024
The case revolves around the taxation treatment of receipts received by Interquest Informatics Services, a Netherlands-incorporated company, under agreements with Schlumberger Seaco, Inc., operating in Pakistan. Interquest claimed the receipts as “business profits,” invoking Article 7 of the Netherlands-Pakistan Double Taxation Convention (DTT) to exempt them from Pakistani taxation. However, the Pakistani tax authorities treated these as “royalties” under Article 12, subjecting them to a 15% income tax.