Minimum tax on income of certain persons
Previously, non-resident companies are excluded from the purview of minimum tax under section 113. The Finance Act has enhanced the scope of section 113 by imposing minimum tax on permanent establishments (PEs) of a non-resident company.
It is pertinent to mention here that Double Tax Agreement (DTA) between Pakistan and other country allows taxation of (PEs) of a non-resident company only on net income basis and the applicability of minimum tax may be challenged in scenarios where DTA prevails.
