Convention between the government of the Islamic Republic of Pakistan and the government of the Repbulic of Latvia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance

OF PAKISTAN REVENUE DIVISION FEDERAL BOARD OF REVENUE * * * NOTIFICATION (Income Tax) Islamabad, the November 01, 2024 S.R.O. 1734 (1)/2024.- WHEREAS the Islamic Republic of Pakistan an 1th public of Latvia signed the Convention for the Elimination of Double Taxation wi 4pec o Taxes on 28tIyIncome and the Prevention of Tax Evasion and Avoidance on the April, 2023 at Warsaw, Poland, as set out in the Annexure to this Notification (th AND WHERAS, in terms of Article 29 of the Cony on, e Governments of the Contracting States shall notify each other in writing thro matic channels when the constitutional requirements for the entry into force of this Co ven on have been complied with."; NOW, THEREFORE, in exercise of the pow ferred by sub-section (1) of section 107 of the Income Tax Ordinance, 2001 (XLIX oi Jthe Federal Government is pleased to direct that the provisions of the Convention shall v afect: (a) in Pakistan, - (i) with regard to taxe d at source, in respect of amounts paid or credited on or after the first ly next following the date upon which the Convention enters into forc • (ii) with re -Nother taxes, in respect of taxable years beginning on or after the first5rp. i next following the date upon which the Convention enters into for (ltin Latvia, - respect of taxes withheld at source, on income derived on or after the first Vday of January in the calendar year next following the year in which the Convention enters into force; and (ii) in respect of other taxes on income and taxes on capital, for taxes chargeable for any fiscal year beginning on or after the first day of January in the calendar year next following the year in which the Convention enters into force.

CONVENTION BETWEEN THE GOVERNMENT OF THE ISLAMIC REPUBLIC OF PAKISTAN AND THE GOVERNMENT OF THE REPUBLIC OF LATVIA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXE INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANC, PREAMBLE The Government of the Islamic Republic of Pakistan and tht oveent of the Republic of Latvia, (hereinafter referred to as Contracting States), Desiring to further develop their economic relations to enhance their co-operation in tax matters, Intending to conclude a Convention for the elimination of double taxation with respect to taxes on income without creating opportunities non-taxation or reduced taxation through tax evasion or avoidance (including through treat g arrangements aimed at obtaining reliefs provided in this Convention for the indirect benefit residents of third jurisdictions), Have agreed as folitws

CHAPTER I SCOPE OF THE CONVENTION Article 1 PERSONS COVERED This Convention shall apply to persons who are residents of one or both of the Contra States. Article 2 TAXES COVERED 1. This Convention shall apply to taxes on income imposed on b ha ntracting State or of its political subdivisions or local authorities, irrespective of in which they are levied. There shall be regarded as taxes on income all tax ed on total income, or on elements of income, including taxes on gains from the al on of movable or immovable property, as well as taxes on the total amounts of wages salanes paid by enterprises. The existing taxes to which the Conventio ar-ply are in particular: a) in Latvia: the enterprise in uznemumu ienakuma nodoklis); the person tax (iedzivotaju ienakuma nodoklis); (here' referred to as "Latvian tax"); b) in P income tax and the super tax; (her 1? referred to as "Pakistan tax"). 4 The Convention shall apply also to any identical or substantially similar taxes that are imposed aftkcithe date of signature of the Convention in addition to, or in place of, the existing taxes. The copetent authorities of the Contracting States shall notify each other of any significant changes which have been made in their taxation laws. CHAPTER II DEFINITIONS Article 3 GENERAL DEFINITIONS 1. For the purposes of this Convention, unless the context otherwise requires:

the term "Latvia" means the Republic of Latvia and, when used in the geographical sense, means the territory of the Republic of Latvia and any other area adjacent to the territorial waters of the Republic of Latvia within which under the laws of Latvia and in accordance with international law, the rights of Latvia may be exercised with respect to the sea bed and its sub-soil and their natural resources; the term "Pakistan" when used in a geographical sense means Pakistan as defined in the constitution of the Islamic Republic of Pakistan and includes any area o the territorial waters of Pakistan which under the laws of Pakistan and inte law is an area within which Pakistan exercises sovereign rights an ve jurisdiction with respect to the natural resources of the seabed an JIjT and superjacent waters; the terms "a Contracting State" and "the other ContractingAState_mean Latvia or Pakistan, as the context requires; the term "person" includes an individual, a company and apy other body of persons; the term "company" means any body corpor te iy entity that is treated as a body corporate for tax purposes; 0 the terms "enterprise of a Contractin d "enterprise of the other Contracting State" mean respectively an ente 7se (-carried on by a resident of a Contracting State and an enterprise carried on esident of the other Contracting State; the term "international traffic" means any transport by a ship, aircraft or railway vehicle operated by an enteyprise of a Contracting State, except when the ship, aircraft or railway vehietejs operated solely between places in the other Contracting State; h) the ter "tent authority" means: tvia, the Ministry of Finance or its authorised representative; in Pakistan, the Federal Board of Revenue or its authorised representative; e term "national" means: any individual possessing the nationality of a Contracting State; any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State. 2. As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.

Article 4 RESIDENT For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, how r, does not include any person who is liable to tax in that State in respect only of income from s in that State or capital situated therein. Where by reason of the provisions of paragraph 1 an individual is M' re f both Contracting States, then his status shall be determined as follows: a) he shall be deemed to be a resident only of the State as a permanent home available to him; if he has a permanent home i. leQh1m in both States, he shall be deemed to be a resident only of the te i which his personal and economic relations are closer (centre of vital inte if the State in which he has his centre of vital sts cannot be determined, or if he has not a permanent home available to in either State, he shall be deemed to be a resident only of the State in whi s an habitual abode; if he has an habitual abode in both-States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; if he is a national of b0Sfates or of neither of them, the competent authorities of the Contracting Statefthall, settle the question by mutual agreement. Where by reason of ions of paragraph 1 a person other than an individual is a resident of both Contracjig es, the competent authorities of the Contracting States shall endeavour to dete Ate niatual agreement the Contracting State of which such person shall be deemed to be resi e purposes of the Convention, having regard to its place of effective management, the p ere it is incorporated or otherwise constituted and any other relevant factors. I e absence of such agreement, such person shall not be entitled to any relief or exempt id by this Convention except to the extent and in such manner as may be agreed upoif the petent authorities of the Contracting States. Article 5 PERMANENT ESTABLISHMENT For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. The term "permanent establishment" includes especially:

a place of management; a branch; an office; a factory; a workshop;, a warehouse; a permanent sales exhibition or sales outlet, and h) a mine, an oil or gas well, a quarry or any other place of extr f natural resources. 3. The term "permanent establishment" is deemed to include: a) a building site, a construction, assembly, installat or upervisory activities in connection therewith, but only where such site, or activities continue for a period of more than six months; the furnishing of services, including c y and managerial services, by an enterprise through employees or oth el engaged by an enterprise for such purposes, but only where activities ature continue (for the same or a connected project) within the Contracting period or periods exceeding in the aggregate 183 days in any twelve-mffl¼ePöd commencing or ending in the fiscal year concerned; activities carried onA o wnA aia contracting state in connectionnn with the exploration or exploitation of,th` ser4led and sub-soil and their natural resources, but only if such activities are cprJa4in for a period or periods exceeding in the aggregate 30 days in any twe rrikith, eriod. The duration of act iesinder subparagraphs a), b) and c) shall be determined by aggregating the periods during which activities in a Contracting State are carried on by closely related enterprises, provide, the Activities of an enterprise in that Contracting State are connected with the activities - attracting State carried on by its closely related enterprises. The period during which two or more closely related enterprises are carrying on concurrent activities shall be counted on l.) once for the purpose of determining the duration of activities. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: the use of facilities solely for the purpose of storage, or display of goods or merchandise belonging to the enterprise; the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display;

the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; the maintenance of a fixed place of business solely for any combination its mentioned in sub-paragraphs a) to e), provided that the overall aVvi :ixed place of business resulting from this combination is of a prepara auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2 but subject to the provisions of paragraph 6, where a person is acting in a Contracting State on behalf of an enterprise and, in doing so, habitually concludes contracts, or habitually plays the princral role leading to the conclusion of contracts that are routinely concluded without material modification brthe enterprise, and these contracts are: a) in the name of the enterprise; or for the transfer of the ownership of, or forthe ling of the right to use, property owned by that enterprise or that the enterpris aithi right to use; or for the provision of services by rise, that enterprise shall be deemed to ermanent establishment in that Contracting State in respect of any activities which t n undertakes for the enterprise, unless the activities of such person are limited to tho e ned in paragraph 4 which, if exercised through a fixed place of business, would not fixed place of business a permanent establishment under the provisions of that p An enterpri of a Eontracting State shall not be deemed to have a permanent establishment in the other Contract g State merely because it carries on business in that other State through a broker, ne 1 colikicnission agent or any other agent of an independent status, provided that such personsaredii iA the ordinary course of their business. However, when the activities of such an enf are voted wholly or almost wholly on behalf of that enterprise, and conditions are made between that enterprise and the agent in their commercial and financial relations which _er fr m those which would have been made between independent enterprises, he will not be codered an agent of an independent status within the meaning of this paragraph. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

CHAPTER III TAXATION OF INCOME Article 6 INCOME FROM IMMOVABLE PROPERTY Income derived by a resident of a Contracting State from immovable Pt) luding income from agriculture or forestry) situated in the other Contracting States_m4 Aied in that other State. The term "immovable property" shall have the meaning whThli it has under the law of the Contracting State in which the property in question is situated. e term shall in any case include property accessory to immovable property, livestock and eq ent used in agriculture and forestry, rights to which the provisions of general law respecti d property apply, any option or similar right to acquire immovable property, usufruct o ovable property and rights to variable or fixed payments as consideration for the g of, or the right to work, mineral deposits, sources and other natural resources. Shi aft and railway vehicles shall not be regarded as immovable property. 3. The provisions of paragraph 1 shal o income derived from the direct use, letting, or use in any other form of immovable pr Where the ownership of other corporate rights in a company entitles the owner of such shares or corporate rig enjoyment of immovable property held by the company, the income from the direct u ting, or use in any other form of such right to enjoyment may be taxed in the Contracmg n which the immovable property is situated. L The provis ns o aragraphs 1, 3 and 4 shall also apply to the income from immovable property of an enterp and to income from immovable property used for the performance of indepen ersolaservices. Article 7 BUSINESS PROFITS 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. However, profits derived from the sale of goods or merchandise of the same or similar kind as those sold, or from other business activities of the same or similar kind as those effected, through that permanent establishment may be considered attributable to that permanent

establishment if it is established that such sales or activities were structured in a manner intended to avoid taxation in the State where the permanent establishment is situated. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently witMe enterprise of which it is a permanent establishment. L a) In the determination of the profits of a permanent establishmpt, thereal be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establishment, including executive and ttngral administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. b) However, no such deduction shall be allowed i specf amounts, if any, paid (otherwise than towards reimbursement of a xpenses) by the permanent establishment to the head office of the enterpris e y of its other offices, by way of royalties, fees or other similar paymeMs in re for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the casF4 a banking enterprise, by way of interest on moneys lent to the permanent establishment. Likewise, no account shall be taken, in the determination of the *tits of a permanent establishment, for amounts charged (otherwise than towards reimbursement of actual expenses), by the permanent establishmerit to the head office of the enterprise or any of its other offices, by way ofalties, tees or other similar payments in return for the use of patents or other rigrldS, or by way of commission for specific services performed or for management. or, except in the case of a banking enterprise, by way of interest on m neyr.lent to the head office of the enterprise or any of its other offices. Lik no account shall be taken, in the determination of the profits of a pe neni establishment, for amounts charged (otherwise than towards reimfIn ent of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other payments in return for the use of patents or other rights, or by way of ommission for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest or moneys lent to the head office of the enterprise or any of its other offices. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.

No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. Where profits include items of income which are dealt with separately in other Articl f this Convention, then the provisions of those Articles shall not be affected by the provisio i Article 8 INTERNATIONAL TRAFFIC Profits derived by an enterprise of a Contracting State from the operation of ships, aircraft or railway vehicles in international traffic shall be taxable only in that Contracting State. Notwithstanding the provisions of paragraph 1, pr ved by an enterprise of a Contracting State from the operation of ships in interVion ffic may be taxed in the other Contracting State, but the tax imposed in that other Stall be reduced by an amount equal to 50 per cent thereof. However, the tax so charged 21,1, ZY exceed 4 per cent of gross amount received. 3. For the purposes of this Article, prof enterprise from the operation of ships, aircraft or railway vehicles in international traffic profits from the rent eboat basis of ships, aircraft or railway vehicles; and profits from theAtis aintenance or rental of containers (including trailers and related eqt4eht(or the transport of containers) used for the transport of goods or mer where such rentai'h$ use, maintenance or rental, as the case may be, is incidental to the operation of ships, aircraft or railway vehicles by the enterprise in international traffic. .4. ~ions of paragraph 1 shall also apply to profits from the participation in a pool, a joi4b9sMsSr an international operating agency. Article 9 ASSOCIATED ENTERPRISES 1. Where a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or

b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the pr_cft of that enterprise and taxed accordingly. Where a Contracting State includes in the profits of an enterprise of thl St axes accordingly - profits on which an enterprise of the other Contracting State has bra. ed to tax in that other State and the profits so included are profits which would have ac-crued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Convention and the competent authorities of the Contracting States shall if necessary consult each other. 3. The provisions of paragraph 2 shall not apply w L e judicial, administrative or other legal proceedings have resulted in a final ruling that by actiols ving rise to an adjustment of profits = under paragraph 1, one of the enterprises concerned is liatile to penalty with respect to fraud, gross negligence or willful default. Article 10 AVIDENDS Dividends paid by a compa'y -filch is a resident of a Contracting State to a resident of the other Contracting State may he taxe in that other State. However, Ctdividends may also be taxed in the Contracting State of which the company paying the dividei is a resident and according to the laws of that State, but if the beneficial owner of the dividfftd,s4s' a resident of the other Contracting State, the tax so charged shall not exceed 1 er cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. The term "dividends" as used in this Article means income from shares, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.

The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. Where a company which is a resident of a Contracting State derives profits or inco WIT the other Contracting State, that other State may not impose any tax on the dividendsdLWthe company, except insofar as such dividends are paid to a resident of that other state4br rnfio ar as the holding in respect of which the dividends are paid is effectively connected vermanent establishment or a fixed base situated in that other State, nor subject the co distributed profits to a tax on the company's undistributed profits, even if J2e s paid or the undistributed profits consist wholly or partly of profits or income other State. Article 11 INTEREST Nk, Interest arising in a Contracting State and paictrffa.resident of the other Contracting State may be taxed in that other State. However, such interest may also be tijie Contracting State in which it arises and according to the laws of that State, but if ti -ficial owner of the interest is a resident of the other Contracting State, the tax so chargiJ not exceed 10 per cent of the gross amount of the interest. Notwithstanding the prTT f paragraph 2, interest arising in a Contracting State, and paid to the Government of theother ontracting State, including its political subdivisions and local authorities, the Central Bank or ahy financial institution wholly owned by that Government shall be exempt from tax in the firsi-mentioned State. The term "interest" as used in this Article means income from debt-claims of every kind, whether orjot secured by mortgage and whether or not carrying a right to participate in the debtor's profits,iñd, in particular, income from government securities and income from bonds or debentures 4uding premiums and prizes attaching to such securities, bonds or debentures. The „term "interest" shall not include any income which is treated as a dividend under the provisions of %rade . Penalty charges for late payment shall not be regarded as interest for the purpose of th rticle. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.

Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt- claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions ot this Article shall apply only to the last-mentioned amount. In such case, the excess part of the ay ents shall remain taxable according to the laws of each Contracting State, due regard be had to the other provisions of this Convention. Article 12 ROYALTIES AND FEES FOR TECHNIC SERVICES 1. Royalties or fees for technical services arising Coftti mg State and paid to a resident of the other Contracting State may be taxed in that othe ate. 2. However, such royalties or fees for techni es may also be taxed in the Contracting State in which they arise and according to the hat State, but if the beneficial owner of the royalties or fees for technical services is a r the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross am f the royalties or fees for technical services. 3. a) The term "royalties" "as used in this Article means payments of any kind received as a consideratio of the use of, or the right to use, any copyright of literary, artistic or scientific iiTiding cinematograph films, or films or tapes or other means of im ge reproduction for television or radio broadcasting, any patent, tra gn or model, plan, secret formula or process, or for the use of, or the use, industrial, commercial or scientific equipment, or for information conc industrial, commercial or scientific experience. rm "fees for technical services" as used in this Article means payments of y kind, other than those in connection with a building site or construction, assembly or installation project mentioned in paragraph 3 of Article 5, or other than those mentioned in Articles 14 and 15, received as a consideration for managerial or technical or consultancy services, including the services of technical or other personnel.

4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. Royalties or fees for technical services shall be deemed to arise in a Contractin en the payer is a resident of that State. Where, however, the person paying the royal es for technical services, whether he is a resident of a Contracting State or not, has in a, mg State - a permanent establishment or a fixed base in connection with which the liability to pa the royalties or fees for technical services was incurred, and such royalties or fees for techniTal services are borne by such permanent establishment or fixed base, then such,- allies or fees for technical services shall be deemed to arise in the State in which the perman-ent ablishment or fixed base is situated. Where, by reason of a special relationship between t er and the beneficial owner or between both of them and some other person, the aman''' t of e royalties or fees for technical services, having regard to the use, right or informatio ffthch they are paid, exceeds the amount which would have been agreed upon by the payer=an the- eneficial owner in the absence of such - relationship, the provisions of this Article shall-appl} only to the last-mentioned amount. In such case, the excess part of the payments shall rain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. Article 13 CAPITAL GAINS *4r •1 . Gains derived b a-r resident of a Contracting State from the alienation of immovable property referred tL4r icle 6 and situated in the other Contracting State may be taxed in that other State. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting take orEsimovable property pertaining to a fixed base available to a resident of a Contracting te in/the other Contracting State for the purpose of performing independent personal services, inc ding such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. Gains derived by an enterprise of a Contracting State from the alienation of ships, aircraft or railway vehicles operated in international traffic or movable property pertaining to the operation of such ships, aircraft or railway vehicles, shall be taxable only in that Contracting State.

4. Gains from the alienation of shares of the capital stock of a company, or of an interest in a partnership, trust or estate, the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that State. In particular: Nothing contained in this paragraph shall apply to a company, partnership, trust or estate, other than a company, partnership, trust or estate engaged in the business of management of immovable properties, the property of which consists directly or indirectly principally of immovable property used by such company, partnership trust or estate in its business activities. For the purposes of this paragraph, "principally" in relationo to ,ownership of immovable property means the value of such immovable propertrceeding fifty percent of the aggregate value of all assets owned by the company, partnership, trust or estate. 5. Gains from the alienation of any property other than tha to paragraphs 1, 2, 3 and 4 shall be taxable only in the Contracting State of which th.Jienat s a resident. Article 14 INDEPENDENT PERSON SERVICES Income derived by an individual who is iit of a Contracting State in respect of professional services or other activities of an ent character shall be taxable only in that State unless he has a fixed base regularly afilaffI to him in the other Contracting State for the purpose of performing his activities. If such a fixed base, the income may be taxed in the other State but only so much of it as table to that fixed base. For this purpose, where an individual who is a resident of a g State stays in the other Contracting State for a period or periods exceeding in the aggJ days in any twelve month period commencing or ending in the fiscal year concerned,:haTrbe deemed to have a fixed base regularly available to him in that other State and the income that is derived from his activities referred to above that are performed in that c heSt hail be attributable to that fixed base. The term " sional services" includes especially independent scientific, literary, artistic, dntational or teaching activities as well as the independent activities of physicians, lawyers, trw ; 'architects, dentists and accountants. Article 15 DEPENDENT PERSONAL SERVICES 1. Subject to the provisions of Articles 16, 18, 19 and 20 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

11111116. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned, and the remuneration is paid by, or on behalf of, an employer who is not a re the other State, and c) the remuneration is not borne by a permanent establishment or a fixe se which the employer has in the other State. fr% 3. Notwithstanding the preceding provisions of this Article, re rived in respect of an employment exercised aboard a ship, aircraft or railway v op ed in international traffic by an enterprise of Contracting State may be taxed in thaCS,tate. Article 16 DIRECTORS' FEES AND RE NERATION OF TOP-LEVEL MANAGERIAL OFFICIALS Directors' fees and other similar remunerationterived by a resident of a Contracting State in his capacity as a member of the board ctors or any other similar organ of a company which is a resident of the other Contrai State may be taxed in that other State. Salaries, wages and other arrinuneration derived by a resident of a Contracting State in his capacity as an official in-4a eel managerial position of a company which is a resident of the other Contracting Stateuay be taxed in that other State. Article 17 ARTISTES AND SPORTSPERSONS Not\vithstaling the provisions of Articles 14 and 15, income derived by a resident of a Contracting, Staas an entertainer, such as a theatre, motion picture, radio or television artiste, or a ffusician., or as a sportsperson, from his personal activities as such exercised in the other ontracting State, may be taxed in that other State. Where income in respect of personal activities exercised by an entertainer or a sportsperson in his capacity as such accrues not to the entertainer or sportsperson himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.

3. The provisions of paragraphs 1 and 2 shall not apply to income derived from activities exercised in a Contracting State by an entertainer or a sportsperson if the visit to that State is wholly or mainly supported by public funds of one or both of the Contracting States or political subdivisions or local authorities thereof. In such case, the income shall be taxable only in the Contracting State of which the entertainer or sportsperson is a resident. Article 18 PENSIONS AND SOCIAL SECURITY PAYMENTS Subject to the provisions of paragraph 2 of Article 19, pensions and e ilar remuneration paid to a resident of a Contracting State in consideration of past t t shall be taxable only in that State. Notwithstanding the provisions of paragraph 1 of this Article and paragraph 2 of Article 19, pensions and other similar remuneration paid under a public scheme which is part of the social security system of a Contracting State or a political subdivision or a local authority thereof shall be taxable only in that State. Article 19 GOVERNMENT 1. a) Salaries, wages and other similar ration, other than a pension, paid by a Contracting State or a politdiu ivision or a local authority thereof to an individual in respect of sers ezdered to that State or subdivision or authority shall be taxable only in tilat _ -_, b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Con acting State if the services are rendered in that other State and the individual i ent of that State who: nal of that State; or NI" not become a resident of that State solely for the purpose of rendering the services. y pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that oilier State. 3. The provisions of Articles 15, 16, 17, 18 and 20 shall apply to salaries, wages and other similar remuneration, and to pensions, in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.

Article 20 STUDENTS Payments which a student, an apprentice or a trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first- mentioned State solely for the purpose of his education or training, receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such pay ts arise from sources outside that State. Notwithstanding the provisions of Article 15, remuneration which a student. or an apprentice or trainee who is or was, immediately before visiting a Contracting State, a esident of the other Contracting State and who is present in the first-mentioned Stateoolely for the purpose of his education or training, receives for dependent personal services rendered in that first- mentioned State shall not be taxable in that State, provided that such services are directly related, and incidental, to his education or training or the remuneration for those services is necessary to supplement the resources for his maintenance. However, in any ease th benefits of this paragraph shall not be granted for a period of more than two consecutili& m the date of his first arrival in the first-mentioned State. Article 2 - OTHER Items of income of a resident of a CCcg State, wherever arising, not dealt with in the foregoing Articles of this Convention s able only in that State. The provisions of paragraph„ 1 hall not apply to income, other than income from immovable property as defined in para aph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment ituated therein, or performs in that other State independent personal services from a fix tinged therein, and the right or property in respect of which the income - is paid is effective ted with such permanent establishment or fixed base. In such case the provisions of Articl Article 14, as the case may be, shall apply. 3. mg the provisions of paragraphs 1 and 2, items of income of a resident of a Contra te not dealt with in the foregoing Article of this Convention and arising in the other Con tate may also be taxed in that other State in accordance with domestic laws. CHAPTER IV METHODS FOR THE ELIMINATION OF DOUBLE TAXATION Article 22 ELIMINATION OF DOUBLE TAXATION 1. In Latvia, double taxation shall be eliminated as follows:

Where a resident of Latvia derives income which, in accordance with this Convention, may be taxed in Pakistan, unless a more favourable treatment is provided in its domestic law, Latvia shall allow: as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Pakistan. Such deduction shall not, however, exceed that part of the income tax in Latvi computed before the deduction is given, which is attributable, to the inco may be taxed in Pakistan. For the purposes of sub-paragraph a), where a company that is arsifitoTLatvia receives a dividend from a company that is a resident of Pa ch it owns at least 10 per cent of its shares having full voting rights, the 'd in Pakistan shall include not only the tax paid on the dividend, but also the • . oropriate portion of the tax paid on the underlying profits of the company out of which the dividend was paid. 2. In Pakistan double taxation shall be eliminated as follp a) Where a resident of Pakistan derives come which, in accordance with the provisions of this Convention, may Ickitl in Latvia whether directly or by deduction, Pakistan shall allow as du2t1on from the tax on the income of that resident an amount equal to the in tax paid in Latvia. The amount of the tax to ted pursuant to the above provision shall not exceed the lesser of the h would have been charged on the same income in Pakistan under the ra able therein. b) Where a resident istan derives income which, in accordance with the provisions of this Convention, shall be taxable only in Latvia, Pakistan may include this inom in the tax base but only for purposes of determining the rate of tax on suc other income as is taxable in Pakistan. 3. Where, in aortfance with the law of a Contracting State, an exemption from, or a reductio axes covered by this Convention is granted for the purpose of encouraging economic develo gContracting State, the tax which would have been paid but for such exemption or all be deemed to have been paid for the purposes of paragraphs 1 and 2 of this s provision, however, is applicable only for the first ten years during which this n is effective. This period may be extended by mutual agreement between the competent au ities. The Contracting States shall notify each other of such agreement through diplomatic channels. CHAPTER V SPECIAL PROVISIONS Article 23

NON-DISCRIMINATION 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States. Stateless persons who are residents of a Contracting State shall not be subjec e Contracting State to any taxation or any requirement connected therewith, which is ore burdensome than the taxation and connected requirements to which natioaJs e State concerned in the same circumstances, in particular with respect to resi4ne, or may be subjected. The taxation on a permanent establishment which an ente aig6ntracting State has in the other Contracting State shall not be less favourably levied C. hat or State than the taxation levied on enterprises of that other State carrying on the same actfiies. Except where the provisions of paragraph 1 of Article,„9., paragraph 7 of Article 11, or paragraph 6 of Article 12 apply, interest, royaltiçsfces for technical services and other disbursements paid by an enterprise of a Contractin tto a resident of the other Contracting State shall, for the purpose of determining the tbprofits of such enterprise, be deductible under the same conditions, including applicajthtofaxes, as if they had been paid to a resident of the first-mentioned State. Enterprises of a Contractin& e capital of which is wholly or partly owned or controlled, directly or indirectly, byñt. oimore residents of the other Contracting State, shall not be subjected in the first-menti e4Si to any taxation or any requirement connected therewith which is other or more burd e than the taxation and connected requirements to which other similar enterprises „Othe entioned State are or may be subjected. The provis s o his Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind a escription. , Article 24 MUTUAL AGREEMENT PROCEDURE here a person considers that the actions of one or both of the Contracting States result or wiiiaresult for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.

The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of Convention. They may also consult together for the elimination of double taxation in provided for in the Convention. The competent authorities of the Contracting States may communicate willch other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, may develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article. Where, under paragraph 1, a person has prese ase to the competent authority of a Contracting State on the basis that c ns of one or both of the Contracting States have resulted for that person ta ion not in accordance with the provisions of this Convention, and the competent authorities are unable to reach an agreement to resolve that case pursuant to paragraph 2 within two years from the date when all the information required by the competent authorities in order to address the case has been provided to both competent authorities, any unresolved issues arising from the case shall be submitted to arbitration if the person so requests in writing. These unresolved issues shall not, however, be submitted to arbitration if a decision on these issues has already been rendered by a court or administrative tribunal of either State. Unless a person directly affected by the case does not accept the mutual agreement that implements the arbitration decision, that decision shall be binding on both Contracting States and shall be implemented notwithstanding any time limits in the domestic laws of these States. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this paragraph. Article 25 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 o determination of appeals in relation to the taxes referred to in paragraph 1, or the oversi above. Such persons or authorities shall use the information only for such purposes ay disclose the information in public court or in judicial proceedings. Notwithstanding going, information received by a Contracting State may be used for other purposes ormation may be used for such other purposes under the laws of both States and the co • authority of the supplying State authorizes such use. 3. In no case shall the provisions of paragraphs 1 and 2 biecoriArned so as to impose on a Contracting State the obligation: to carry out administrative measures at vani t the laws and administrative practice of that or of the other Contracti Stat to supply information which is not obt nder the laws or in the normal course of the administration of that or of • ontracting State; to supply information whi disclose any trade, business, industrial, commercial or professional secrtr trade process, or information the disclosure of which would be contraryj6uMic policy (ordre public). 4. If information is requestec Motracting State in accordance with this Article, the other • Contracting State shall use its informaion gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation containe e *ceding sentence is subject to the limitations of paragraph 3 but in no case shall suc be construed to permit a Contracting State to decline to supply information solelycau it has no domestic interest in such information. 5. case shall the provisions of paragraph 3 be construed to permit a Contracting State to declin nformation solely because the information is held by a bank, other financial ins 'nee or person acting in an agency or a fiduciary capacity or because it relates to n erests in a person. .>„ Article 26 ASSISTANCE IN COLLECTION OF TAXES 1. The Contracting States shall lend assistance to each other in the collection of revenue claims. This assistance is not restricted by Articles 1 and 2. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this Article.

The term "revenue claim" as used in this Article means an amount owed in respect of 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 this Convention or any other instrument to which the Contracting States are parties, as well as interest, administrative penalties and costs of collection or conservancy related to such amount. When a revenue claim of a Contracting State is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its collection, that revenue claim shall, at the request of the competent authority of that State, be-' accepted for purposes of collection by the competent authority of the other Contractin&Stite. That revenue claim shall be collected by that other State in accordance with the provisionSlt its laws applicable to the enforcement and collection of its own taxes as if the revenue clai revenue claim of that other State. When a revenue claim of a Contracting State is a claim in res that State may, under its law, take measures of conservancy with a view to ensure it 11ctin, that revenue claim shall, at the request of the competent authority of that State, b acce for purposes of taking measures of conservancy by the competent authority of the ot Contracting State. That other State shall take measures of conservancy in respect of that r e aim in accordance with the provisions of its laws as if the revenue claim were a re ue of that other State even if, at the time when such measures are applied, the reve 1 im is not enforceable in the first- mentioned State or is owed by a person who has a ri prevent its collection. Notwithstanding the provisions of paragi aphi 3 and 4, a revenue claim accepted by a Contracting State for purposes of paragraph 3 or 4 shall not, in that State, be subject to the time limits or accorded any priority applicable to a revenue claim under the laws of that State by reason of its nature as such. In addition, a revenue claim accepted by a Contracting State for the purposes of paragraph 3 or 4 shall not, in that have any priority applicable to that revenue claim under , State) the laws of the other Contract* 'State _ Proceedings with reto the existence, validity or the amount of a revenue claim of a Contracting State ,s1411 riot 4 brought before the courts or administrative bodies of the other Contracting State. Where, at any me after a request has been made by a Contracting State under paragraph 3 or 4 a_ Bfore the other Contracting State has collected and remitted the relevant revenue claim to the,firl-s "ndd State, the relevant revenue claim ceases to be: No, in the case of a request under paragraph 3, a revenue claim of the first-mentioned State that is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its collection, or b) in the case of a request under paragraph 4, a revenue claim of the first-mentioned State in respect of which that State may, under its laws, take measures of conservancy with a view to ensure its collection,

the competent authority of the first-mentioned State shall promptly notify the competent authority of the other State of that fact and, at the option of the other State, the first-mentioned State shall either suspend or withdraw its request. 8. In no case shall the provisions of this Article be construed so as to impose on a Contracting State the obligation: to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; to carry out measures which would be contrary to public policy (ordre to provide assistance if the other Contracting State has not pursued a thable measures of collection or conservancy, as the case may be, iwaiab1j,i r its laws or administrative practice; to provide assistance in those cases where the adminisaIiv r1i for that State is clearly disproportionate to the benefit to be derive er Contracting State. Article 27 MEMBERS OF DIPLOMATIC MISSIONV NSULAR POSTS Nothing in this Convention shall affect th privileges of members of diplomatic missions or consular posts under the general rule rnational law or under the provisions of special agreements. icle 28 ENTIT4EMNT TO BENEFITS Notwithstanding the otbej xwions of this Convention, a benefit under this Convention shall not be granted in respe46 Eem of income if it is reasonable to conclude, having regard to all relevant facts ad ci stäiices, that obtaining that benefit was one of the principal purposes of any arrangeme4 or ion that resulted directly or indirectly in that benefit, unless it is established that grkiting t • enefit in these circumstances would be in accordance with the object and purpose of the reigont provisions of this Convention. bela berth under this Convention is denied to a person under paragraph 1, the co etniuffity of the Contracting State that would otherwise have granted this benefit shall eat that person as being entitled to this benefit, or to different benefits with respect a s item of income, if such competent authority, upon request from that person and after side ation of the releiTant facts and circumstances, determines that such benefits would have be ranted to that person, or to another person, in the absence of the transaction or arrangement referred to in paragraph 1. The competent authority of the Contracting State to which the request has been made will consult with the competent authority of the other State before rejecting the request made under this paragraph by a resident of that other State. CHAPTER VI FINAL PROVISIONS

Article 29 ENTRY INTO FORCE The Governments of the Contracting States shall notify each other in writing through diplomatic channels when the constitutional requirements for the entry into force of this Convention have been complied with. The Convention shall enter into force on the date of the later of the notifications re to in paragraph 1 and its provisions shall have effect: a) in Latvia: in respect of taxes withheld at source, on income derAd n or:'fter the first day of January in the calendar year next following e- r in which the Convention enters into force; in respect of other taxes on income and tax- on camtal, for taxes chargeable for any fiscal year beginning on or a -I first day of January in the calendar year next following the year In winch the Convention enters into force. b) in Pakistan: (i) with regard to taxes at source, in respect of amounts paid or credited on or after t ay of July next following the date upon which the Convention force; and (ii) with regar r taxes, in respect of taxable years beginning on or after the first July next following the date upon which the Convention ente i orce. Article 30 TERMINATION ThisCorn entipn shall remain in force until terminated by a Contracting State. Either Contracting Statemay terminate the Convention, through diplomatic channels, by giving written notice of termination at least six months before the end of any calendar year starting five years 'after the year in which the Convention entered into force. In such event, the Convention shall cease 7' ave effect: a) in Latvia: (i) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; (ii) in respect of other taxes on income and taxes on capital, for taxes chargeable for any fiscal year beginning on or after the first day of January in the calendar year next following the year in which the notice has been given;

• b) in Pakistan: in respect of taxes withheld at source, for other taxes, for amounts paid or credited and for taxable periods on or after the first day of July next following the date on which written notice of termination is given. IN WITNESS WHEREOF, the undersigned, duly authorized thereto, have signed this Convention. Done in duplicate at Warsaw this 28th day of April 2023, in the Latvian and English la both texts being equally authentic. In the case of divergence of interpretation, the Engl 1 prevail. - Sd - For the Government of the Islamic For the Govcrn 'e Republic Republic of Pakistan atvi

PROTOCOL At the signing of the Convention between the Government of the Republic of Latvia and the Government of the Islamic Republic of Pakistan for the avoidance of double taxation with respect to taxes on income, the undersigned have agreed that the following provisions shall form an integral part of the Convention. With respect to Article 11, paragraph 3: It is understood that a financial institution wholly owned by the Government of a Contracting State is: in Latvia: the Development Finance Institution "Altum"; in Pakistan: the State Bank of Pakistan, the National Bank f and the Export- Import Bank of Pakistan; any other institution similar to those mentioned in su ara phs a) and b), and agreed by mutual agreement between the competent authoriis of tVContracting States. With respect to Article 13: It is understood that in the case of Latvia, the provisi ragraph 1 of Article 13 also apply to income from the alienation of immovable propert to in Article 6 and situated in Latvia. With respect to Article 23: It is understood that nothing in this Art be construed as obliging a Contracting State to grant to residents of the other Contracting e any personal allowances, reliefs or reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. With reference to paragr rticle 24: the competent aut of the Contracting States shall by mutual agreement establish a procedure in order en re that an arbitration decision will be implemented within two years from a request for arbi ration as referred to in paragraph 5 of Article 24 of the Convention unless actions or inaction of a person directly affected by the case in respect of which the request for arbitration has been made hinder the resolution of the case or unless the competent authorities of the Contracting States and that person otherwise agree; an arbitration panel shall be established in accordance with the following rules: an arbitration panel shall consist of three arbitrators who are individuals with expertise or experience in international tax matters; each of the competent authorities of the Contracting States shall appoint one arbitrator, whether he is a national of either Contracting State or not. The two arbitrators appointed by the competent authorities of the Contracting States shall appoint the third arbitrator who serves as the chair of the arbitration panel in

accordance with the procedures agreed by the competent authorities of the Contracting States; no arbitrator shall be an employee of the tax authority of either Contracting State, nor have dealt with the case in respect of which the request for arbitration has been made in any capacity. The third arbitrator shall not be a national of either Contracting State, nor have had his usual place of residence in either Contracting State, nor have been employed by either Contracting State; Ft& - the competent authorities of the Contracting States shall ensure that at! a rtrators agree, in statements sent to each of the competent authorities of the Contraeing States, prior to their acting in an arbitration proceeding, to abide by and be §-ubjeZ4 c;11* same confidentiality and non-disclosure obligations as those descri edi:e ragfaph 2 of Article 25 of the Convention and under the laws of the Contract s; each of the competent authorities of the Contractin esNrbear the costs of thia arbitrator and other its appointed arbitrator and its own expenses. The cott o expenses associated with the conduct of the arbitratr procoedings shall be borne by the competent authorities of the Contracting State ettual shares; c) the competent authorities of the Contracting States sl1 p e the information necessary for the arbitration decision to all arbitrators without undu clef d) an arbitration decision shall be treated as folk an arbitration decision has n ttal value; an arbitration decision-shall- e final, unless that decision is found to be unenforceable by a cou affeither Contracting State due to a violation of paragraph 5 of Article 24 of the C n, of this paragraph or of any procedural rule determined in accordance with graph a) that may reasonably have affected the decision. If the decision is4hd to be unenforceable due to the violation, the request for arbitratjshfiiT considered not to have been made and the arbitration process shall be co tt to have taken place (except for the purposes of clauses (iv) and (v) of sub agraph b)); any time before the arbitration panel has delivered a decision on a case to the e) wher competaiMns of the Contracting States and to the person who made the request for arb _espect of the case: (i) the competent authorities of the Contracting States reach a mutual agreement to resolve the case pursuant to paragraph 2 of Article 24 of the Convention; or (ii) that person withdraws the request for arbitration; or (iii) a decision concerning the case is rendered by a court or administrative tribunal of either Contracting State during the arbitration proceedings, the procedures under Article 24 of the Convention in respect of the case shall terminate; 0 where a case in respect of which a request for arbitration has been made is pending in litigation or appeal, the mutual agreement that implements the arbitration decision on the case shall be

considered not to be accepted by the person directly affected by the case if any person directly affected by the case who is a party to the litigation or appeal does not withdraw, within 60 days after receiving the decision of the arbitration panel, from consideration by the relevant court or administrative tribunal all issues resolved in the arbitration proceedings. In this case, the case shall not be eligible for any further consideration by the competent authorities of the Contracting States; g) the provisions of paragraph 5 of Article 24 of the Convention and this paragraph shall not apply to cases falling within paragraph 3 of Article 4 of the Convention; IN WITNESS WHEREOF, the undersigned, duly authorized thereto, have signed thi Pr Done in duplicate at Warsaw this 28th day of April 2023, in the Latvian and ngl1iivages, both texts being equally authentic. In the case of divergence of interpretatio thq EgJishctext shall prevail. - Sd Sd - For the Government of the Islamic For the t ernm t of the Republic Republic of Pakistan Latvia C.No.2(5)Int.Taxes/96-L AT (Mir Badshah Khan Wazir) dditional Secretary/Member (Inland Revenue-Operations)