Advance ruling – withholding tax on payments for construction assembly or installation project in Pakistan, including related supervisory activities

The Central Board of Revenue (CBR) of Pakistan has delivered an advance ruling (Advance Ruling No. 6 by CBR) dated 4 July 2007 in the case of a foreign communication services provider working with a Pakistani company. The question raised was whether the income of Telcordia (i.e. the foreign investor) from Pakistan MNP Database (Guarantee) Limited (i.e. the Pakistani company) was liable to withholding tax at 6%, and whether such withholding tax was the final tax liabili…