ARTICLE XIV (Government Banks) 　　(1) Effective January 1, 1956 the State Bank of Pakistan shall be exempted from United States tax with respect to interest from sources within the United States. 　　(2) Effective January 1, 1956 the Federal Reserve Banks of the United States shall be exempted from Pakistan tax with respect to interest from sources within Pakistan. ARTICLE XV (Avoidance of Double Taxation) 　　(1) Subject to the provisions of the Internal Revenue Code (as in effect on the date of signature of the present Convention) regarding the allowance of a credit against United States tax for tax payable in a territory outside the United States, Pakistan tax payable, whether directly or by deduction, in respect of income from sources within Pakistan shall he allowed as a credit against United States tax payable in respect of that income. [For the purposes of this credit there shall be deemed to have been paid by a United States domestic corporation the amount by which such Pakistan taxes (other than the business profits tax) have been reduced under the provisions of section 15B of the Income Tax Act, 1922 (XI of 1922) as in effect on the date of the signature of the present Convention: Provided, That any extension made by law of the period within which an industrial undertaking may be set up or commenced in order to obtain the reduction provided in section 15B shall be deemed to be in effect on the date of the signature of the present Convention.] 　　(2) Subject to the provisions of Pakistan income tax law (as in effect on the date of signature of the present Convention), United States tax payable, whether directly or by deduction, by a person resident in Pakistan, in respect of income from sources within the United States (including income accruing or arising in the United States but deemed, under the provisions of the law of Pakistan, to accrue or arise in Pakistan) shall be allowed as a credit against any Pakistan tax payable in respect of that income. 　　(3) For the purposes of this Article, profits or remuneration for personal (including professional) services performed in one of the contracting States shall be treated as income from sources within that State. ARTICLE XVI (Mutual Assistance) 　　(1) The taxation authorities of the contracting States shall exchange such information (being information which is available under their respective taxation laws in the normal course of administration) as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or for the administration of statutory provisions in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or trade process. 　　(2) The taxation authorities of the contracting States may consult together, as may be necessary, for the purpose of carrying out the provision of the present Convention and in particular the provisions of Article III and IV. Where a taxpayer claims that he has been or may be subjected to double taxation contrary to the provisions of the present Convention, he may present the facts to the taxation authorities of either contracting State. Should the taxpayer's claim be deemed worthy of consideration, the taxation authorities shall endeavor to come to an agreement with a view to avoidance of the double taxation in question. 　　(3) The taxation authorities of both contracting States may prescribe regulations necessary to interpret and carry out the provisions of the present Convention and may communicate with each other directly for the purpose of giving effect to the provisions of the present Convention. 　　(4) The provisions of the present Convention shall not be construed to restrict in any manner any exemption, deduction, credit or other allowance now or hereafter accorded by the laws of either contracting State in determining the tax of such State. ARTICLE XVII (Limitations on Effect of Treaty) 　　(1) The citizens or nationals of one of the contracting States shall not, while resident in the other contracting State, be subjected in such other State to taxes or any requirement connected therewith which is other, higher or more burdensome than the taxes and connected requirements to which the citizens or nationals of such other State resident therein are or may be subjected. 　　(2) The term "citizens" or "nationals", as used in this Article, includes all legal persons, partnerships and associations deriving their status from, or created or organized under, the laws in force in the respective contracting States. 　　(3) Nothing contained in this Article shall be construed- 　　(a) as obliging either of the contracting States to grant to persons not resident in its territory those personal allowances, reliefs and reductions for tax purposes which are by law available only to persons who are so resident; or 　　(b) as affecting any provisions of the law of Pakistan regarding the imposition of tax on a nonresident or the grant of rebate of tax to companies fulfilling specified requirements regarding the declaration and payment of dividends, unless those requirements are fulfilled. ARTICLE XVIII (Territorial Extension) 　　(1) The present Convention may be extended, either in its entirety or with modifications, to any territory for whose international relations either of the contracting States is responsible and which imposes taxes substantially similar in character to those which are the subject of the present Convention and any such extension shall take effect from such date and subject to such modification and conditions (including conditions as to termination) as may be specified and agreed between the contracting States in notes to be exchanged for this purpose. 　　(2) The termination in respect of Pakistan or the United States of the present Convention under Article XX shall, unless otherwise expressly agreed by both contracting States, terminate the application of the present Convention to any territory to which the Convention has been extended under this Article. ARTICLE XIX (Entry into Force) 　　The present convention shall come into force on the date when the last of all such things shall have been done in the United States and Pakistan as are necessary to give the Convention the force of law in the United States and Pakistan, respectively, and shall thereupon have effect- 　　(a) In the United States, for the taxable years beginning on or after the first day of January of the year in which the instruments of ratification are exchanged; 　　(b) In Pakistan, in respect of the "previous years" or the "chargeable accounting periods" (as defined by the tax laws of Pakistan) beginning on or after the first day of January of the year in which the instruments of ratification are exchanged. ARTICLE XX (Termination) 　　The present Convention shall continue in effect indefinitely but either of the contracting States may, on or before the 30th day of June in any calendar year not earlier than three years from the date of signature of the present Convention, give to the other contracting State written notice of termination and, in such event the present Convention shall cease to be effective - 　　(a) in the United States, for the taxable years beginning on or after the first day of January next following such written notice of termination; and 　　(b) in Pakistan, in respect of the "previous years" or the "chargeable accounting periods" (as defined by the tax laws of Pakistan) beginning on or after the first day of January next following such written notice of termination. 　　IN WITNESS WHEREOF, the respective Plenipotentiaries have signed this Convention and have affixed thereto their seals. 　　DONE in duplicate at Washington this first day of July, 1957. FOR THE GOVERNMENT OF THE 　　　　　　　　　　　　　FOR THE GOVERNMENT UNITED STATES OF AMERICA: 　　　　　　　　　　　　　OF PAKISTAN: (s) John Foster Dulles 　　　　　　　　　　　　　　 (s) Mohammed Ali 　　　　　　　　　　　　　　　　　　　　　　　　　　(s) S. Amjad Ali 　　AND WHEREAS the Senate of the United States of America by their resolution of July 9, 1958, two-thirds of the Senators present concurring therein, did advise and consent to the ratification of the aforesaid convention "subject to the reservation, which shall be agreed to by the other high contracting party before ratifications are exchanged, that the second sentence of paragraph 1 of Article XV shall not be ratified"; 　　AND WHEREAS the text of the aforesaid reservation was communicated by the Government of the United States of America to the Government of Pakistan and was agreed to by the Government of Pakistan; 　　AND WHEREAS the aforesaid convention was duly ratified by the President of the United States of America on November 6, 1958, in pursuance of the aforesaid advice and consent of the Senate and subject to the aforesaid reservation, and was duly ratified on the part of the Government of Pakistan; 　　AND WHEREAS the respective instruments of ratification of the aforesaid convention were duly exchanged at Karachi on May 21, 1959, and a protocol of exchange was signed at that place and on that date by the respective Plenipotentiaries of the United States of America and Pakistan; 　　AND WHEREAS it is provided in Article XIX of the aforesaid convention that the convention shall have effect (a) in the United States of America, for the taxable years beginning on or after the first day of January of the year in which the instruments of ratification are exchanged, and (b) in Pakistan, in respect of the "previous years" or the "chargeable accounting periods" (as defined by the tax laws of Pakistan) beginning on or after the first day of January of the year in which the instruments of ratification are exchanged; 　　NOW, THEREFORE, be it known that I, Dwight D. Eisenhower, President of the United States of America, do hereby proclaim and make public the aforesaid convention to the end that the said convention and each and every article and clause thereof, subject to the aforesaid reservation, may be observed and fulfilled with good faith, with respect to taxable years beginning on or after January 1, 1959, by the United States of America and by the citizens of the United States of America and all other persons subject to the jurisdiction thereof. 　　IN TESTIMONY WHEREOF, I have hereunto set my hand and caused the Seal of the United States of America to be affixed. 　　DONE at the city of Washington this twenty-eighth day of May in the year of our Lord one thousand nine hundred fifty-nine and of the Independence of the United States of America the one hundred eighty-third. By the President: DWIGHT D. EISENHOWER DOUGLAS DILLON Acting Secretary of State