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DEUTCHE BANK (ASIA) ATIENGESELLCHAFT (Last Login: 22-Jul-2013, 12:15 PM)

0700245-9 - COY (LTU KARACHI)


Saved successfully Application for Exemption on Payments to Non-Resident
NTN: Office : (LTU/RTO) * Commissioner IRS Name: Nature of Payment: * 0700245-9 LTU KARACHI - (34)
(If Known)

Status: Prepared

Name of Payer: Tax Year: Commissioner IRS Zone: *

EDN No.: DEUTCHE BANK (ASIA) ATIENGESELLCHAFT 2012 Zone II Amount Due for Payment: * Date of Notice:

34090339 22/07/2013

Section 152(2) – ANY OTHER AMOUNT except PKR Section - Ruppee (PK) Currency: * an amount to which


Particulars of Payer
Status of the Payer: PE Of Non Resident

PE of Non-Resident Person in Pakistan: BOI/EAD's Permission No. Residence Country: Main Business: Contact Details: Address* Tel #:* Website: Total Payment made Under the head during the year: Total Payment to the Recipient During the Year: Remitting Bank Particulars: Bank Name (Local): * Address: * DEUTSCHE BANK AG Branch Code : * 004201 243-243, AVARI PLAZA, FATIMA JINNAH ROAD, KARACHI. 009221111555777 Fax: Inc. /Reg. No.: 372/20001007 E-mail:* Inc./ Reg. Date: azhar.iqbal@db.com Germany BANKING Date: Status in Home Country: Corporate NTN: STRN: 0700245-9


Particulars of Recipient
Category: Contact Details: Corporate Address: * Country:* E-mail:* Incorporation #: Bank Account Details: A/C No. : * Branch Address:* Tel.# : Currency: Currency: PKR - Ruppee (PK) Select... 14000010193902 Bank Name: * DEUTSCHE BANK AG TAUNUSANLAGE 12, 60262, FRANKFURT AM MAIN, GERMANY Germany alexander.sonntag@db.com Tel#:* Website: Inc.Date: 049699103640 www.db.com Fax: Corporate Name of Recipient: * DEUTSCHE BANK AG

DEUTSCHE BANK AG, PO BOX 100601, FRANKFURT Country:* Germany

Total Payment to the Recipient during the Year: Total Payment to the Recipient to-date:

Particulars of Transactions
Is the contract one-time or ongoing ? Nature of Contract?(What gives rise to the payments): * Attach Copy of Contract/Agreement Nature of Payment * Total Payment: Currency: * Section 152(2) – ANY OTHER AMOUNT except an amount to which Section PKR - Ruppee (PK) Amount: * 708236000 Pertains to which Tax Year: * 2012 Ongoing remittance of after tax branch profit of Rs 708.236 million pertaining to the accounting year 2011 (Tax Year 2012)


Basis of Exemption
Is the Claim based on an Agreement for the Avoidance of Double Taxation(ADTA)? Country:* Germany Yes

Applicable Article/Paragraph:* Article 10(4) read with Article 7 of the Avoidance of Double Taxation Treaty between Pakistan and Germany Other Supporting Arguments?(Please make out your case for exemption by making cogent arguments duly supported by legal provisions/data and documents) * Requested On: Save Submit 22/07/2013 1) As per Article 10(3) of the treaty, the term ‘Dividends’ means income from shares OR income from other corporate right which is subject to same taxation as dividend on shares by the taxation law of Pakistan in which the company making the payment is a resident. Considering the first part, it is amply clear that the enlarged definition as per the domestic law will not be applicable for DB. Even considering the second part, it is also clear that DB-Pakistan (the company making the payment) is not a "resident" in Pakistan. Application No. 147

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