The Supreme Court of Pakistan issued an order on 28 November 2024 concerning the treatment of software payments under the 1982 income and capital tax treaty with the Netherlands. The case involved a company incorporated in the Netherlands that received payments for software under agreements with a company operating in Pakistan. In its returns, the Dutch companies declared the receipts as business profits and sought an exemption under Article 7 of the 1982 tax treaty. However, the Pakistan ta…