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  "title": "Foreign Investment (Promotion and Protection) Act, 2022",
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  "text": "Page 1 of 29 \r\n \r\n \r\nTHE FOREIGN INVESTMENT (PROMOTION AND PROTECTION) ACT, \r\n2022 \r\n \r\n \r\n \r\n \r\n \r\n \r\nCONTENTS \r\n           __________ \r\nSECTIONS: \r\n1.  Short title, extent, application and commencement. \r\n2. Definitions. \r\n3. Notification and protection of qualified investments and investment incentives. \r\n4. Investment incentives. \r\n5.  Investment agreement. \r\n6.  Implementation of investment incentives. \r\n7. Implementation of investment incentives by Federal Government and Federal Government \r\nentities. \r\n8. Creation of security. \r\n9.  Secrecy of banking transaction. \r\n10.  Immunities to protected accounts. \r\n11.  Investor obligations.  \r\n12.  Investment ombudsman. \r\n13.  Jurisdiction and powers of the investment ombudsman. \r\n14. Relationship with other laws.  \r\n15.  Power to make rules. \r\n16.  Removal of difficulties. \r\n \r\n \r\n\r\n \r\nPage 2 of 29 \r\n \r\nTHE FOREIGN INVESTMENT (PROMOTION AND PROTECTION) ACT, \r\n2022 \r\n \r\nACT NO. XXXV OF 2022 \r\n[13th December, 2022] \r\nAN \r\nACT \r\nto provide for promotion and protection of certain qualified foreign investments and for matters \r\nincidental thereto \r\nWHEREAS it is expedient and in the national interest to attract, encourage, and protect, large \r\nscale foreign investment into Pakistan and to ensure sustainable economic activity and growth; \r\nAND WHEREAS it is necessary to improve the investment climate in Pakistan by way of \r\nproviding incentives in direct and indirect taxes and ease of transfer and repatriation of foreign \r\ninvestments to the large scale foreign investments and by protecting such incentives from withdrawal; \r\nAND WHEREAS it is essential for the Federal Government, the Provincial Government, and \r\nthe local governments and other relevant authorities to work together and cooperate to ensure provision \r\nof incentives and protection to the qualified investments; \r\nAND WHEREAS the Provincial Assemblies of Balochistan and Sindh have each passed a \r\nresolution under Article 144 of the Constitution of the Islamic Republic of Pakistan to the effect that \r\nMajlis-e-Shoora (Parliament) may by law regulate certain matters enumerated in this Act and whereas \r\nthe Provincial Assemblies of Khyber Pakhtunkhwa and the Punjab may do so in the future; \r\nAND WHEREAS in relation to qualified investments, the Provincial Assemblies of Balochistan \r\nand Sindh have each passed a resolution under Article 147 of the Constitution of the Islamic Republic \r\nof Pakistan authorising the Federal Government to declare as protected benefits any notification issued \r\nby a Provincial Government under a provincial law and whereas the Provincial Assemblies of Khyber \r\nPakhtunkhwa and the Punjab may do so in the future; \r\nIt is hereby enacted as follows:— \r\n1. Short title, extent, application and commencement.—(1) This Act shall be called the \r\nForeign Investment (Promotion and Protection) Act, 2022. \r\n(2) It extends to the whole of Pakistan 1[but for the purpose of Balochistan Province, it shall \r\nonly apply to the qualified investment of Reko Diq project as mentioned in schedules and annexures \r\nof this Act]. \r\n(3) It shall come into force at once. \r\n(4) It shall be applicable to all qualified investments along-with such incentives as enacted or \r\nnotified by the Federal Government from time to time. \r\n \r\n1Added by the Foreign Investment (Promotion and Protection) (Amdt.) Act No. XXXVI of 2022 s.2. \r\n \r\nPage 3 of 29 \r\n \r\n2. Definitions.—(1) In this Act (including the Schedules), unless there is anything repugnant \r\nin the subject or context.— \r\n(a)  “concerned Government” means the Federal Government, any Federal \r\nGovernment entity or any Provincial Government, as the case may be; \r\n(b) “enterprise” means any organisation, whether incorporated or not, including \r\nany company, corporation (including any non-profit corporation), limited \r\nliability company, limited duration company, branch of a foreign company, \r\nassociation, organization, foundation, fund, general partnership, limited \r\npartnership, limited liability partnership (in each case, registered or un-\r\nregistered), joint venture, joint stock association, an association of persons, firm, \r\nsociety, trust, or any other legal person, enterprise, association, organization or \r\nentity as may be recognized under the laws of any jurisdiction; \r\n(c) “export processing zone” means an area that is declared to be a zone for the \r\npurposes of the Export Processing Zones Authority Ordinance, 1980; \r\n(d)  “Federal Government” means the Government of the Islamic Republic of \r\nPakistan; \r\n(e) “Federal Government entity” means any public sector company as defined \r\nunder section 2(54) of the Companies Act 2017 (Act XIX of 2017), any agencies \r\nor instrumentalities of the Federal Government, including but not limited to any \r\nministry, division, department, commission or office of the Federal Government \r\nas well as any authority or enterprise set up or established under and pursuant \r\nto federal legislation, autonomous or semi-autonomous body, local body, and \r\nany other entity fully or majority owned or controlled by the Federal \r\nGovernment, and/or quasi- governmental or non-government organizations \r\ngiven authority by governmental entities or organizations at any level of \r\ngovernment, and includes the State Bank of Pakistan and any local or municipal \r\nauthority or statutory body within the ICT; \r\n(f) “financial institution” means a financial intermediary, bank or other enterprise \r\nthat is authorized to do business and regulated or supervised as a financial \r\ninstitution or bank under the laws of Pakistan; \r\n(g)  “Government servant” means a civil servant as defined in the Civil Servants \r\nAct, 1973 (LXXI of 1973) or under a Provincial Civil Servants Act, and includes \r\nany person in the service of any statutory body or Federal Government entity or \r\nProvincial Government entity; \r\n(h)  “ICT” means the Islamabad Capital Territory; \r\n(i)  “investment” includes any asset that an investor owns or controls, directly or \r\nindirectly, that has the characteristics of an investment, including such \r\ncharacteristics as the commitment of capital or other resources, the expectation \r\nof gain or profit, the assumption of risk, and, without limiting the generality of \r\nthe foregoing, an investment may take the following forms:— \r\n(i)  an enterprise; \r\n \r\nPage 4 of 29 \r\n \r\n(ii)  shares, stock, and other forms of equity participation in an enterprise; \r\n(iii) bonds, debentures, any Islamic financing arrangements, hedge \r\ninstruments, other debt instruments and loans; \r\n(iv) an interest in an enterprise that entitles the owner to share in the assets \r\nof that enterprise on dissolution; \r\n(v)  futures, options and other derivatives; \r\n(vi)  an interest arising from the commitment of capital or other resources, \r\nincluding under turnkey, construction, management, production, \r\nconcession, revenue-sharing, and other similar contracts; \r\n(vii)  intellectual property rights; \r\n(viii)  exemptions, leases, licenses, authorizations, permits, permissions, and \r\nsimilar rights conferred by a concerned Government (including mining \r\nleases, exploration licenses, surface rights and water rights); \r\n(ix)  insurance policies; \r\n(x) rights under contracts; and \r\n(xi)  other tangible or intangible, movable or immovable property, and \r\nrelated property rights such as leases, licenses, liens, mortgages, \r\npermissions, permits and pledges, and the term “invest” shall have a \r\ncorresponding meaning; \r\n(j)  “investment agreement” means an agreement entered into between an investor \r\nand any one or more concerned Governments in respect of a qualified \r\ninvestment providing investment incentives that are protected benefits as \r\ncontemplated in this Act; \r\n(k)  “investment incentive” includes— \r\n(i) an exemption, wholly or partially, from any Federal or provincial or \r\nlocal charges, cesses, duties, fees, levies, taxes or tolls payable under \r\nany law; \r\n(ii)  payment of any Federal or provincial or local charges, cesses, duties, \r\nfees, levies, taxes, or tolls at such rates, which are less than the rates \r\nspecified in the applicable law; \r\n(iii)  payment of any Federal or provincial or local charges, cesses, duties, \r\nfees, levies, taxes, or tolls on goods, services or contracts only at such \r\nrates as are applicable at the time an Investment Agreement is signed; \r\n(iv) an exemption from the operation or application of any provision of any \r\nlaw, regulation, rule, ordinance or other similar instrument; \r\n \r\nPage 5 of 29 \r\n \r\n(v)  a license or lease or permit or permission granted or conferred by a \r\nconcerned Government; \r\n(vi)  licenses or permissions for the import and export of fuel, lubricants, \r\nchemicals, catalysts, minerals, raw materials, components, spare parts, \r\nmachinery, and equipment; \r\n(vii)  grant or renewal of work permits; \r\n(viii)  licenses, approvals, no objections, consents, permissions, or permits for \r\nthe remittance to or repatriation of foreign exchange from or into \r\nPakistan; and/or \r\n(ix)  a right granted and regulated under any law applicable within the \r\nterritory of Pakistan, including licenses to explore for, cultivate, extract, \r\nprocess, transport, sell or exploit natural resources; \r\n(l)  “investor” means (i) a foreign natural person or enterprise who invests or has \r\ninvested in Pakistan, including (1) foreign enterprises and any of their respective \r\ndirect and indirect agents, contractors, successors, assigns, lenders, directors, \r\nemployees, servants and service providers, (2) direct and indirect shareholders \r\nof an investor referred to in clause (i) and (3) any Pakistani subsidiary that is \r\ndirectly or indirectly owned or controlled by an investor referred to in clause (i), \r\nor (ii) any other enterprise established under the laws of Pakistan who invests \r\nin Pakistan that is chosen, approved and duly notified by the Federal \r\nGovernment as an investor under this Act; \r\n(m)  “protected account” means a bank account established within Pakistan or \r\noutside of Pakistan in any unit or currency by an investor in connection with a \r\nqualified investment; \r\n(n)  “protected benefit” means the investment incentives provided to investors \r\nand/or qualified investments through legislative amendments contained in the \r\nSecond Schedule of this Act as well as all investment incentives listed in the \r\nThird Schedule of this Act; \r\n(o)  “Province(s)'”means the Province of Balochistan, Khyber-Pakhtunkhwa, the \r\nPunjab and Sindh, or any one of them, as the context may require; \r\n(p)  “Provincial Government” means the government of a Province and any \r\nProvincial Government entity; \r\n(q)  “Provincial Government entity” means a public sector company as defined \r\nunder section 2(54) of the Companies Act 2017 (Act XIX of 2017), any agencies \r\nor instrumentalities of a Provincial Government, including but not limited to \r\nany ministry, division, department, commission or office of a Provincial \r\nGovernment as well as any authority or enterprise set up or established under \r\nand pursuant to provincial legislation, autonomous or semi-autonomous body, \r\nlocal body, and any other entity fully or majority owned or controlled by a \r\nProvincial Government, and/or quasi-governmental or non-government \r\n \r\nPage 6 of 29 \r\n \r\norganizations given authority by governmental entities or organizations at any \r\nlevel of government; \r\n(r) “qualified investment” means the investments, sectors, industries or projects \r\nas may be chosen, approved and duly notified by the Federal Government as a \r\nqualified investment in the First Schedule to this Act; and \r\n(s)  “Schedule” means a Schedule to this Act and includes the First Schedule, the \r\nSecond Schedule and the Third Schedule. \r\n3. Notification and protection of qualified investments and investment incentives.—(1) All \r\ninvestments, sectors, industries or projects listed in the First Schedule to this Act shall be deemed to \r\nbe qualified investments. \r\n(2) The Federal Government may notify additional investments, sectors, industries or projects \r\nas qualified investments through a notification in the official Gazette amending the First Schedule to \r\nthis Act. \r\n(3) The Federal Government may choose and approve qualified investments on such terms and \r\nconditions and for such duration as deemed in the national interest: \r\nProvided that no investment shall be notified as a qualified investment unless the amount to be \r\ninvested (whether in the form of equity or debt) is not less than US$ 500 million (or its equivalent in \r\nPak Rupees): \r\nProvided further that the Federal Government may, for reasons to be recorded, notify an \r\ninvestment as a qualified investment even if the amount to be invested therein is less than US$ 500 \r\nmillion (or its equivalent in Pak Rupees). \r\n(4) The Federal Government may provide such investment incentives to qualified investments \r\nand/or the investors who have made an investment in such qualified investment on such terms and \r\nconditions and for such duration as may be notified or, as applicable, implemented through further \r\nlegislation, from time to time. \r\n(5) The legislated amendments provided in the Second Schedule to this Act and the investment \r\nincentives listed in the Third Schedule to this Act shall be applicable to such qualified investments as \r\nshall be specified therein. \r\n(6) The Federal Government may notify such additional investment incentives to be protected \r\nbenefits for such period, in relation to such qualified investments, and on such conditions, as the \r\nFederal Government deems appropriate, through a notification in the official Gazette amending the \r\nSecond Schedule or the Third Schedule, as applicable: \r\nProvided that the Federal Government may notify only such investment incentives to be \r\nprotected benefits which are necessary or desirable as a consequence or in connection with the \r\nresolution of international commitments or which are expected to accrue such substantial benefits to \r\nPakistan which justify their inclusion as protected benefits. \r\n(7) The Federal Government may not amend the First Schedule so as to remove a qualified \r\ninvestment. \r\n \r\nPage 7 of 29 \r\n \r\n(8) The Federal Government may not amend the Second Schedule nor the Third Schedule so \r\nas to remove a protected benefit. \r\n(9) Investment incentives under this Act (including for certainty those provided in the Second \r\nSchedule and the Third Schedule) shall be in addition to all incentives, benefits and protections, which \r\nmay be applicable to a foreign investment and/or the investors therein under generally applicable \r\nlegislation and international agreements of Pakistan. \r\n(10) The rights conferred on investors by the provisions of this Act (including the Schedules) \r\nshall continue to be available to such investors to the extent of their qualified investments even if this \r\nAct is repealed or amended, unless the repealing or amending law expressly provides otherwise. \r\n(11) A protected benefit that is a legislated amendment shall continue in force for the term \r\nspecified in the Second Schedule and a protected benefit that is listed in the Third Schedule shall \r\ncontinue in force for the term specified in the Third Schedule (including any underlying notification \r\nreferenced therein), as applicable, and shall not be withdrawn or modified, altered in any manner \r\n(whether prematurely or retrospectively) or superseded or substituted in any manner that dis-\r\nadvantages or operates to the detriment of any qualified investment or any investor that has made an \r\ninvestment in such qualified investment. \r\n(12) If a statute on the basis of which a protected benefit has been provided is itself amended \r\nin a manner that operates to the dis-advantage of any qualified investment or any investor that has \r\nmade an investment in such qualified investment, the un-amended statute shall be deemed to continue \r\nin force with respect to the qualified investment and such investor, unless and until the amended statute \r\nexpressly provides that it is intended to be with prejudice to the qualified investment, an investor or a \r\nprotected benefit. \r\n(13) If a concerned Government commits to an investor in an investment agreement or pursuant \r\nto this Act that no Federal, provincial or local charges, cesses, duties, fees, taxes, levies or tolls, \r\nincluding any requirement to make contributions to advance local, social or community matters, other \r\nthan those agreed will be applicable to a qualified investment, whether then or later, then such \r\ncommitment shall amount to an actionable obligation, the breach of which shall entitle the investor to \r\nappropriate relief against the concerned Government, whether in the form of damages or through \r\ninjunctive relief, from any court or tribunal of competent jurisdiction: \r\nProvided that no concerned Government may make any such commitment unless the relevant \r\nagreement with the investor containing such commitment has been reviewed and approved by the \r\nFederal Cabinet or the Cabinet of the Provincial Government concerned, as the case may be. \r\n4. Investment incentives.—(1) The following categories of incentives, among others, may be \r\ngranted to investors or to, or in respect of, qualified investments, to be commenced from the date of \r\napproval of such qualified investment and the inclusion of such investment incentive in the Second \r\nSchedule or the Third Schedule, namely: — \r\n(a) exemption from or concession on some or all taxes under the Income Tax \r\nOrdinance, 2001 including tax on profits and gains, income tax, turnover tax, \r\nwithholding tax on interest, capital gains tax, income tax on dividend income \r\nand withholding tax on dividend; \r\n \r\nPage 8 of 29 \r\n \r\n(b)  provisions relating to anti avoidance under the Income Tax Ordinance, 200l \r\n(XLIX of 2001) or any other legislation may not be applicable to qualified \r\ninvestments; \r\n(c)  exemption from or concession on sales tax under the Sales Tax Act, 1990 and \r\nsales tax on services under respective provincial laws; \r\n(d)  exemption from the capital value tax under section 8 of the Finance Act, 2022 \r\n(XIII of 2022) or any other tax similar in nature; \r\n(e)  exemption from or concession on customs duty under the Customs Act, 1969 \r\non the import into Pakistan of all capital goods including but not limited to, \r\nplant, equipment, machinery, components, catalysts, raw materials, spare parts, \r\nhardware, software, devices, instruments, accessories, attachments, building \r\nmaterials, materials and any other equipment required to perform functions of \r\nenterprises located in an export processing zone or related qualified \r\ninvestments, whether or not manufactured locally, for use by an investor; \r\n(f)  exemption from or concession on any export duty or similar duty, cess or levy \r\non the export from Pakistan of any products produced in Pakistan or raw \r\nmaterials, equipment, machinery, components, catalysts, spare parts, hardware, \r\nsoftware, devices, instruments, accessories and other materials no longer \r\nrequired by an investor in connection with a qualified investment; \r\n(g)  exemption from or concession on Federal excise duty; \r\n(h)  exemption from or concession under any specific directions, guidelines or \r\ninstructions issued under the Banking Companies Ordinance, 1962 (LVII of \r\n1962), Foreign Exchange Regulations Act, 1947 (VII of 1947) or any similar \r\nlaw or regulation, as may be specified in the Third Schedule; \r\n(i)  exemption from or concession on property tax; \r\n(j)  exemption or remission from, or concession on, stamp duty and/or registration \r\nfees levied by the Federal Government, a Federal Government entity or a \r\nProvincial Government; \r\n(k)  the project area of a qualified investment, as well as any bank branches of \r\ninternational or local banking institutions located at the same premises as the \r\noffices established in connection with such qualified investment, may be \r\ndeclared as an export processing zone entitled to the exemptions and \r\nconcessions available to export processing zones under the Export Processing \r\nZones Authority Ordinance, 1980 (IV of 1980) and all the rules made, or SROs \r\nissued thereunder, may be stabilized, subject to any additional incentive as may \r\nbe prescribed by a concerned Government; \r\n(l) stabilizing a royalty rate negotiated and agreed with a Provincial Government; \r\n(m)  exemption from or concession on application of federal and/or provincial labour \r\nand social welfare laws including laws pertaining to workers participation in \r\ncompanies' profits and workers welfare fund; \r\n \r\nPage 9 of 29 \r\n \r\n(n)  exemption from or concession on levy of federal and/or provincial development \r\nand or infrastructure development cess or whatever name it is called; \r\n(o) permission to any qualified investment declared as an export processing zone \r\nor an enterprise or investor operating in an export processing zone for opening, \r\nmaintaining and operation of foreign currency accounts outside Pakistan or \r\nwithin Pakistan to the extent these accounts are located in an export processing \r\nzone and relate to the qualified investment, and to freely bring, hold, retain off-\r\nshore, buy, sell, transfer, expatriate and take out foreign currency from or to \r\nsuch accounts, in any form without delay and without any requirement to make \r\na foreign exchange declaration at any stage or to satisfy any other requirement, \r\nto meet the requirements of Investors, lenders, contractors, operators, \r\nconsultants, insurers, re-insurers, vendors, contract counterparties and advisors \r\nin relation to any compensation amounts, payments, loan repayments, equity \r\nand return on equity, profits, works, goods and services; \r\n(p)  in respect of any qualified investment declared as an export processing zone or \r\nan investor operating in an export processing zone, access to non-discriminatory \r\nrates for foreign exchange transactions if deemed appropriate; and \r\n(q) exemption from or concession on any Federal or provincial or local charges, \r\ncesses, duties, fees, levies, taxes or tolls by whatever name called. \r\n5.  Investment agreement.— Any agreement entered into between an investor and one or \r\nmore concerned Governments in respect of a qualified investment providing investment incentives that \r\nare protected benefits shall be deemed to be an investment agreement that has been entered into \r\npursuant to this Act. \r\n6.  Implementation of investment incentives.— The concerned Governments, shall ensure \r\nthe implementation of protected benefits granted to investors and the qualified investments under this \r\nAct and any investment agreement mentioned in section 5. \r\n7. Implementation of investment incentives by Federal Government and Federal \r\nGovernment entities.— The Federal Government and Federal Government entities will facilitate \r\nqualified investments within Pakistan by inter alia— \r\n(a) creating the enabling environment for investments; \r\n(b)  streamlining and simplifying procedures for investment applications and \r\napprovals; \r\n(c)  enacting or amending laws, or rules or regulations or issuing any statutory \r\nnotifications in order to implement and effectuate qualified investments and \r\nprotected benefits; \r\n(d)  ensuring expeditious processing of requests and applications and issuance of \r\nany approvals, permits, consents, notifications or certifications required for \r\ncarrying out business and operations under and pursuant to qualified \r\ninvestments; \r\n \r\nPage 10 of 29 \r\n \r\n(e)  promoting dissemination of Investment information, including rules, \r\nregulations, policies and procedures; \r\n(f)  establishing one window facilities; \r\n(g)  strengthening databases on investments for policy formulation to improve \r\nPakistan's overall investment environment; \r\n(h)  undertaking consultation with the investors on investment matters;  \r\n(i) providing advisory services if requested by the investors; and \r\n(j) any other actions as may be deemed appropriate by the Federal Government and \r\nFederal Government entities for the purposes of effective enforcement of the \r\nprotected benefits by the Federal Government and Federal Government entities. \r\n8.  Creation of security.— An investor may create security, including through the creation of \r\na lien or charge, over any asset forming part of, or connected with, its qualified investment or protected \r\nbenefits, in favour of or for the benefit of any enterprise that is lending or otherwise providing financing \r\nor funds or guarantees to an investor in connection with a qualified investment. \r\n9.  Secrecy of banking transaction.— Secrecy of banking transactions of an investor in a \r\nqualified investment or of the qualified investment shall be strictly observed by all banks and financial \r\ninstitutions, by whosoever owned, controlled or managed, except as otherwise provided in accordance \r\nwith applicable anti-money laundering laws for the time being in force. \r\n10. Immunities to protected accounts.— (1) A protected account shall enjoy immunity \r\nagainst any inquiry or action from all taxation authorities as to the source of funding of protected \r\naccounts. \r\n(2) The balances in the protected accounts and income therefrom shall continue to remain \r\nexempt from the levy of wealth-tax, income tax or any other tax or compulsory deduction of Zakat at \r\nsource. \r\n11. Investor obligations. (1) The Federal Government shall ensure that, in connection with \r\ndesignating a qualified investment, the investor will commit in the related investment agreement to \r\ncommercially reasonable investor obligations in favour of Pakistan that the Federal Government \r\nconsiders appropriate and in the national interest. \r\n(2) All remedies of the Federal Government or any Federal Government entity for a failure by \r\nthe investor to comply with the obligations referred to in sub-section (1) shall be limited to the remedies \r\nprovided in the investment agreement. \r\n12. Investment ombudsman.— (1) The Federal Government shall appoint an investment \r\nombudsman for a term of three years, on such terms and conditions as may be prescribed by the rules \r\nmade under this Act: \r\nProvided that— \r\n(a)  any such rules made under this Act shall not impose any obligation, \r\ncommitment or duty on, or curtail, impair or otherwise diminish the rights of, \r\nan investor; and \r\n \r\nPage 11 of 29 \r\n \r\n(b)  the investment ombudsman shall not be subject to, or have the powers provided \r\nby, the Federal Ombudsmen Institutional Reforms Act, 2013 (XIV of 2013). \r\n(2) The investment ombudsman shall have at least fifteen years of experience in the field of \r\ninternational trade and foreign investment and related matters. \r\n(3) Until such time that the investment ombudsman is appointed under sub-section (1), the \r\nFederal Government may, by notification designate any government officer or functionary as the \r\ninvestment ombudsman who shall be deemed to be the investment ombudsman under this Act. \r\n13. Jurisdiction and powers of the investment ombudsman.—(1) The investment \r\nombudsman may entertain an application by an investor against a concerned Government regarding \r\nviolation of any of the provisions of this Act or non-implementation of protected benefits by a \r\nconcerned Government and shall work in good faith with an investor and any relevant Government \r\nentity to resolve any such alleged violation and may issue orders or recommendations to ensure \r\nredressal of such grievance within one hundred and twenty days from the date of receipt of such \r\napplication: \r\nProvided that the investment ombudsman will have no suo moto jurisdiction and no authority \r\nto entertain an application by a concerned Government or by any person other than an investor against \r\na concerned Government. \r\n(2) The investment ombudsman may, if the matter requires further probe or information, call \r\nfor such information from or summon such Government servant as is consistent with the authority of \r\na civil court in Pakistan to summon such documents and witnesses. \r\n(3) The investment ombudsman shall have the same powers to punish a Government servant \r\nfor contempt as that of a civil court under the Contempt of Court Ordinance, 2003 (V of 2003). \r\n(4) An application made by an investor pursuant to sub -section (1) shall be without prejudice \r\nand in addition to the right of the affected investor to seek relief from any forum, including any court \r\nor tribunal of competent jurisdiction.  \r\n(5) Without limiting sub-section (5), if a matter referred to the investment ombudsman pursuant \r\nto an application is not settled or resolved to the satisfaction of the affected investor within the one \r\nhundred and twenty days period referred to above, the affected investor shall be free to pursue any and \r\nall legal remedies available to it without further obligation under this Act. \r\n(6) The investment ombudsman may, for the purposes of efficient performance of its functions \r\nor exercise of its powers, appoint such employees as it may consider necessary on such terms and \r\nconditions as may be prescribed by the rules made under this Act. \r\n14.  Relationship with other laws. —(1) Subject to sub-section (2), the provisions of this Act \r\nand the protected benefits provided under this Act, including the Second Schedule and Third Schedule, \r\nshall have effect notwithstanding anything contrary contained in any other law or instrument having \r\nthe force of law for the time being in force and in the event of any conflict between this Act and any \r\nother law whether enacted prior to or subsequent to this Act, the provisions of this Act shall prevail \r\nunless the subsequent law expressly provides that it overrides this Act. \r\n(2) The rights granted to investors (including protected benefits) under this Act are in addition \r\nto all other incentives, protections and rights available to investors in any other law for the time being \r\n \r\nPage 12 of 29 \r\n \r\nin force, provided that in case of any inconsistency the provisions of this Act (including the Schedules) \r\nshall prevail over any other law. \r\n(3) No provision of this Act or any repeal or amendment of this Act shall be construed to \r\nadversely alter, remove, curtail, reduce, limit or otherwise adversely affect the contractual rights of an \r\ninvestor in an investment agreement. \r\n(4) The Schedules are an integral part of this Act and the Act and the Schedules thereto shall \r\nbe read harmoniously. \r\n(5) The statutes affected by the Second Schedule shall stand amended in accordance with the \r\nprovisions of the Second Schedule. \r\n(6) To the extent any protected benefit listed in the Third Schedule relates to any statute being \r\namended through the Second Schedule, such protected benefit shall be deemed to have been issued by \r\nthe concerned Government in the exercise of powers available under the statute as amended by the \r\nSecond Schedule to this Act. \r\n15. Power to make rules.— The Federal Government may, by notification in the official \r\ngazette, make rules for carrying out the purposes of this Act. \r\n16. Removal of difficulties.— The Federal Government may, by order, provide for the \r\nremoval of any difficulty, which may arise in giving effect to the provisions of this Act. \r\n________________ \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\nPage 13 of 29 \r\n \r\nFIRST SCHEDULE \r\nQUALIFIED INVESTMENTS \r\nThe following investments are hereby declared to be qualified investments: \r\n1. The Reko Diq project in the Province of Balochistan in Pakistan, which includes all work \r\ndone by the Reko Diq Mining Company (Private) Limited (formerly Tethyan Copper Company \r\nPakistan (Private) Limited) (“RDMC”) and its associated companies since its date of incorporation as \r\nwell as Reko Diq Phase 1, Reko Diq Phase 2 and all subsequent phases, including all roads, pipelines, \r\npower generation facilities, transmission lines, processing facilities and any other infrastructure used \r\nin or in connection with the Reko Diq project operations, and all lands and orebodies, including \r\nTanjeel, that lie within the mining lease areas granted to RDMC, together with the lands covered by \r\nthe exploration license and surface lease granted to RDMC pursuant to the Implementation Agreement \r\nto be entered into in respect of the Reko Diq project between Barrick Gold Corporation, Oil and Gas \r\nDevelopment Company Limited, Pakistan Petroleum Limited, Government Holdings (Private) \r\nLimited, Balochistan Mineral Resources Limited, Pakistan Minerals (Private) Limited, the Islamic \r\nRepublic of Pakistan and the Province of Balochistan and in connection with the Antofagasta Exit \r\nDeed dated 20 March 2022, between the Islamic Republic of Pakistan, the Province of Balochistan \r\nand Antofagasta plc. \r\nSECOND SCHEDULE \r\nAMENDMENTS TO LAWS \r\nA. Amendments to the Income Tax Ordinance, 2001 (XLIX of 2001) \r\n(1) Certain defined terms. Section 2 of the Income Tax Ordinance, 2001 (XLIX of 2001) shall \r\nbe amended through the insertion of the following defined terms: \r\n“(12A) “commercial production date” in the case of Reko Diq Mining Company (Private) \r\nLimited, means the first day of the month following the date on which Reko Diq \r\nMining Company (Private) Limited issues its first invoice for an aggregate of at \r\nleast 10,000 dry tonnes of concentrate under any agreement, arrangement or \r\nunderstanding entered into by the Reko Diq Mining Company (Private) Limited \r\nor its subsidiaries with any other party providing for the purchase and sale of, or \r\nother disposition of rights in and to, any Product (in the form of ore, concentrate \r\nor otherwise); \r\n(32A) “mineral agreement” means the mineral agreement to be entered into in respect \r\nof the Reko Diq Project between the Islamic Republic of Pakistan, the Province \r\nof Balochistan, Reko Diq Mining Company (Private) Limited and Barrick Gold \r\nCorporation; \r\n(32B) “mineral agreement effective date” means the date on which the mineral \r\nagreement is executed by each of the parties thereto and becomes effective, as \r\nevidenced by the date set out on both the cover page and page 1 of the mineral \r\nagreement; \r\n(45A) “product” in the case of Reko Diq Mining Company (Private) Limited, means any \r\nores, minerals and mineral resources, precious or base, metallic and non-metallic \r\n \r\nPage 14 of 29 \r\n \r\n(and concentrates derived therefrom) mined or otherwise extracted from the Reko \r\nDiq Project; \r\n(47BA) “Reko Diq Mining Company (Private) Limited” means Reko Diq Mining \r\nCompany (Private) Limited (formerly Tethyan Copper Company Pakistan \r\n(Private) Limited) and shall include its successors and its permitted assigns under \r\nthe Mineral Agreement; \r\n(47BB) “Reko Diq Phase l” means the first phase of development of the Reko Diq Project \r\nas set forth in the then-current overall development plan for the Reko Diq Project, \r\nand envisaged as a development with a design capacity of approximately \r\n40,000,000 tonnes of ore per annum of upfront processing capacity; \r\n(47BC) “Reko Diq Phase 2” means the second phase of development of the Reko Diq \r\nProject as set forth in the then-current overall development plan for the Reko Diq \r\nProject, and envisaged as a development to increase the total upfront processing \r\ncapacity of the Reko Diq Project to approximately 80,000,000 tonnes of ore per \r\nannum; \r\n(47BD) “Reko Diq Project” means the Reko Diq project in the Province of Balochistan in \r\nPakistan, which includes all work done by the Reko Diq Mining Company \r\n(Private) Limited and its associated companies since its date of incorporation as \r\nwell as Reko Diq Phase 1, Reko Diq Phase 2 and all subsequent phases, including \r\nall roads, pipelines, power generation facilities, transmission lines, processing \r\nfacilities and any other infrastructure used in or in connection with the Reko Diq \r\nproject operations, and all lands and orebodies, including Tanjeel, that lie within \r\nthe mining lease areas granted to Reko Diq Mining Company (Private) Limited, \r\ntogether with the lands covered by the exploration license and surface lease \r\ngranted to Reko Diq Mining Company (Private) Limited pursuant to the \r\nImplementation Agreement to be entered into in respect of the Reko Diq project \r\nbetween Barrick Gold Corporation, Oil and Gas Development Company Limited, \r\nPakistan Petroleum Limited, Government Holdings (Private) Limited, \r\nBalochistan Mineral Resources Limited, Pakistan Minerals (Private) Limited, the \r\nIslamic Republic of Pakistan and the Province of Balochistan and in connection \r\nwith the Antofagasta Exit Deed dated 20 March 2022, between the Islamic \r\nRepublic of Pakistan, the Province of Balochistan and Antofagasta plc.” \r\n(2) Final Tax Regime (Time limited exemption and rate stabilization). Part II of the Second \r\nSchedule to the Income Tax Ordinance, 2001 (XLIX of 2001) shall be amended through \r\nthe insertion of the following sub-clause: \r\n“(1A) In the case of Reko Diq Mining Company (Private) Limited, during the period \r\nstarting on the Commercial Production Date and expiring on the 15th anniversary \r\nof such date, the rate of tax to be deducted under sub-section (3A) of section 154 \r\nshall be zero %. Prior to the Commercial Production Date and following the I5-\r\nyear period referenced above, the rate of tax to be deducted under sub-section \r\n(3A) of section I54 shall be 1% of Net Smelter Returns and no other tax would be \r\npayable on the said receipts. \r\n \r\n \r\nPage 15 of 29 \r\n \r\nExplanation: \r\nFor the purposes of this sub-section, “net smelter returns” shall be calculated as \r\n“gross proceeds” less “allowable deductions”. \r\nWhere: \r\n“allowable deductions”, for a calendar month, means (without duplication) the \r\nfollowing charges imposed as part of a Sale (but only to the extent actually \r\nincurred by the Licensee) in respect of such calendar month: \r\n(i) charges for treatment in the smelting, refining, retorting, solution extraction, \r\nelectrowinning and any other beneficiation processes (as applicable), but \r\nexcluding any and all costs of or in connection with the activity of mining, \r\nmilling or concentrating; and \r\n(ii)  charges for the presence of deleterious elements that increase smelter or \r\nrefining costs, \r\nAnd, for the avoidance of doubt, does not include any other charge that may be imposed as part \r\nof a Sale (such as taxes, selling and marketing costs, insurance costs, storage costs or cost of \r\ntransportation of any ores, minerals and mineral resources, precious or base, metallic or non-\r\nmetallic (and concentrates derived therefrom) mined or otherwise extracted from the Reko Diq \r\nMining Project to places where such products are smelted, refined or sold). \r\n \r\n“gross proceeds”, for a calendar month, means, the gross proceeds received during such month \r\nby Reko Diq Mining Company (Private) Limited (whether on a provisional or final settlement \r\nbasis) from Sales in respect of payable metal (including, without double counting, in the case \r\nof an insurable loss, the sum of any relevant insurance proceeds received during such month \r\nby Reko Diq Mining Company (Private) Limited or its affiliates); provided that, in the case of \r\nsales to a related party or any other person with whom Reko Diq Mining Company (Private) \r\nLimited is not dealing with at arm's length, the proceeds to be included shall be determined \r\nbased on the applicable market price in the calendar month in which the sale occurred. \r\n“payable metal” means all copper, gold and/or other metal produced or recovered from any \r\nores, minerals and mineral resources, precious or base, metallic or non-metallic (and \r\nconcentrates derived therefrom) mined or otherwise extracted from the Reko Diq Mining \r\nProject by or on behalf of Reko Diq Mining Company (Private) Limited (without double-\r\ncounting). \r\n“sale” means a sale, transfer or other disposition of title of payable metal by or on behalf of the \r\nReko Diq Mining Company (Private) Limited to any person (including to any related party or \r\na person with whom the Reko Diq Mining Company (Private) Limited is not dealing with at \r\narm's length), and is deemed to include (i) a transfer of title to such Payable Metal transported \r\noff the area in relation to which Reko Diq Mining Company (Private) Limited holds a mining \r\nlease that Reko Diq Mining Company (Private) Limited elects to have credited to or held for \r\nits account by another person, and (ii) any insurable loss prior to any transfer or deemed transfer \r\nof title to such payable metal for which compensation is received. For greater certainty, any \r\nsale, transfer or other disposition of title to any such minerals made on a provisional basis and \r\nany subsequent final adjustment in connection therewith shall each constitute a separate sale.” \r\n \r\nPage 16 of 29 \r\n \r\n(3) Dividend income and withholding tax thereon for shareholders (Time limited \r\nexemption and rate stabilization). \r\n(a)  Part I of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of 2001) \r\nshall be amended through the insertion of the following sub-clauses: \r\n“(145B) “Any income of Reko Diq Mining Company (Private) Limited during the period \r\nstarting on the Commercial Production Date and expiring on the 15th anniversary \r\nof such date. \r\n(145C) Any dividend distributed by Reko Diq Mining Company (Private) Limited to a \r\nnon-resident shareholder during the period starting on the commercial production \r\ndate and expiring on the 15th anniversary of such date. \r\nPrior to the commercial production date and following the expiration of the 15th \r\nanniversary of the commercial production date, tax payable (including \r\nwithholding taxes) on distributions from Reko Diq Mining Company (Private) \r\nLimited to its non-resident shareholders shall be taxed at the same applicable rates \r\n(not exceeding 20% depending on the non-resident shareholder's domicile and \r\nafter taking into account the availability of relief from taxes available under the \r\nrelevant clause of any applicable double tax convention) as specified in the First \r\nSchedule to the Income Tax Ordinance, 2001 (XLIX of 2001) as at 20 March \r\n2022, unless any subsequent modified rates are reduced in which case such \r\nreduced rates shall apply to a non-resident shareholder of Reko Diq Mining \r\nCompany (Private) Limited.” \r\n(b) Part IV of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of \r\n2001) shall be amended through the insertion of the following sub-clause: \r\n“(47N)  The provisions of section 150 or any other withholding tax on dividends shall not \r\napply to dividends distributed by Reko Diq Mining Company (Private) Limited \r\nduring the period starting on the Commercial Production Date and ending on the \r\n15th anniversary of such date.” \r\n(c)  Clause 11A of Part IV of the Second Schedule to the Income Tax Ordinance, 2001 \r\n(XLIX of 2001) shall be amended through the insertion of the following sub-\r\nclause: \r\n“(xlvi) Reko Diq Mining Company (Private) Limited for a period of 30 tax years \r\nfollowing the mineral agreement effective date.” \r\n(d)  Part I of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of 2001) \r\nshall be amended through the insertion of the following sub-clauses: \r\n“(150)  Any income (including dividend and the income taxable under section 109A) \r\nderived by Pakistan Petroleum Limited, Oil and Gas Development Company \r\nLimited and Government Holdings (Private) Limited (hereinafter referred to as \r\nthe “SOEs”) from Pakistan Minerals (Private) Limited (the company established \r\nby the SOEs for the purpose of the Reko Diq Project), during the period starting \r\non the mineral agreement effective date and expiring on the 30th anniversary of \r\nsuch date. \r\n \r\nPage 17 of 29 \r\n \r\n(151) Any income (including dividend and the income taxable under 109A) derived by \r\nthe company referred to in clause 150, from any of its associated companies \r\nestablished for the purpose of the Reko Diq Project, during the period starting on \r\nthe mineral agreement effective date and expiring on the 30th anniversary of such \r\ndate. \r\n(152)  Any income (including dividend and income taxable under 109A) derived by the \r\nfollowing during the period starting on the mineral agreement effective date and \r\nexpiring on the 30th anniversary of such date: \r\n(i) a company established by or on behalf of the Government of Balochistan for the \r\npurpose of investment in the Reko Diq Project; and \r\n(ii)  the shareholders of the company referred to in (i).” \r\n(e) Part IV of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of \r\n2001) shall be amended through the insertion of the following sub-clause: \r\n“(38E)  The provisions of section 150 as well as any similar withholding tax provisions \r\nshall not apply on the income exempt from tax under clauses 150, 151 and 152 of \r\nPart I of the Second Schedule during the period starting on the mineral agreement \r\neffective date and expiring on the 30th anniversary of such date.” \r\n(4) Capital gains tax (conditional exemption and rate stabilization). \r\n(a)  Part I of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of 2001) \r\nshall be amended through the insertion of the following sub-clause: \r\n“(47E) For a period of 30 years from the mineral agreement effective date, any income \r\n(including capital gains) on disposal of shares or interests, whether directly or \r\nindirectly, in Reko Diq Mining Company (Private) Limited through share \r\ntransfer, reconstruction, reorganization or amalgamation shall not be subject to \r\nany tax, provided that (A) the ultimate beneficiary of the economic interest in \r\nsuch shares remains Barrick Gold Corporation (or its successors or its permitted \r\nassigns under the joint venture agreement governing the Reko Diq Project) or (B) \r\nsuch disposal arises in the context of enforcement by third party lenders against \r\nany of their security interests in the Reko Diq Project, including shares, \r\nguarantees, or assets thereof including with respect to transfers or assignments of \r\nshares, shareholder loans and/or assets to third parties in respect of shares, \r\nshareholder loans and/or assets that are subject to such lender security interests \r\nprovided that the enforcement and transfer or assignment is part of the same \r\nenforcement proceedings.” \r\n(b) Part III of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of \r\n2001) shall be amended through the insertion of the following sub-clause: \r\n“(21)  For a period of 30 years from the mineral agreement effective date, the capital \r\ngains resulting from any disposal of shares of, or interest in, Reko Diq Mining \r\nCompany (Private) Limited, whether directly or indirectly, in circumstances other \r\nthan those described in (A) or (B) of clause 47E of Part 1 of the Second Schedule \r\nto the Income Tax Ordinance, 2001 (XLIX of 2001) shall be taxed at the \r\n \r\nPage 18 of 29 \r\n \r\napplicable rate (after taking into account the availability of relief from taxes \r\navailable under the relevant clause of any applicable double tax convention) as \r\nspecified in First Schedule to the Income Tax Ordinance, 2001 (XL IX of 2001) \r\nas at 20 March 2022, unless any subsequent modified rates are reduced in which \r\ncase such reduced rates shall apply to the vendor of such shares.” \r\n(5) Withholding tax on shareholder loan interest and shareholder income (time limited \r\nexemption and rate stabilization). \r\n(a)  Part I of the Second Schedule to the Income Tax Ordinance, 200I (XLIX of 2001) \r\nshall be amended through the insertion of the following sub-clause: \r\n“(47F) Any profit on debt derived by a direct or indirect shareholder on account of \r\nshareholder loans provided to or for Reko Diq Mining Company (Private) \r\nLimited, shall not be subject to the provisions of sections 39 and 152(2A) or any \r\nsimilar tax on profit on debt during the period starting on the commercial \r\nproduction date and ending on the 15th anniversary of such date. Prior to the \r\ncommercial production date and following the 15th anniversary of the commercial \r\nproduction date, the provisions of sections 39 and 152(2A) or any similar tax on \r\nprofit on debt at the applicable rate (after taking into account the availability of \r\nrelief from taxes available under the relevant clause of any applicable double tax \r\nconvention) as specified in the First Schedule to the Income Tax Ordinance, 2001 \r\n(XLIX of 2001) as at 20th March, 2022 and no other tax on profit on debt shall \r\napply to the Reko Diq Mining Company (Private) Limited and its direct and \r\nindirect shareholders.” \r\n(b) Part IV of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of \r\n2001) shall be amended through the insertion of the following sub-clause: \r\n“(47G) For a period of 30 years from the mineral agreement effective date, the provisions \r\nof withholding tax on debt in section 151 and 152 as well as any other withholding \r\ntax on debt shall not apply on the income exempt from tax under clause 47F of \r\nPart 1 of the Second Schedule to the Income tax Ordinance, 2001 (XLIX of \r\n2001).” \r\n(6) Withholding tax on third party interest and third party income (conditional \r\nexemption). \r\n(a)  Part I of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of 2001) \r\nshall be amended through the insertion of the following sub-clause: \r\n“(47H) For a period of 30 years from the mineral agreement effective date, any profit on \r\ndebt derived by third party lenders on account of any loan provided to or for Reko \r\nDiq Mining Company (Private) Limited, for the purposes of financing \r\nconstruction or expansion of the Reko Diq Project.” \r\n(b)  Part IV of the Second Schedule to the Income Tax Ordinance, 2001(XLIX of \r\n2001) shall be amended through the insertion of the following sub-clause: \r\n“(47I)  For a period of 30 years from the mineral agreement effective date, the provisions \r\nof withholding tax on profit on debt in sections 151 and 152 as well as any other \r\n \r\nPage 19 of 29 \r\n \r\nwithholding tax on profit on debt shall not apply on the income exempt from tax \r\nunder clause 47H of Part 1 of the Second Schedule to the Income Tax Ordinance, \r\n2001 (XLIX of 2001).” \r\n(7) Thin capitalization (stabilization of existing requirements). Part IV of the Second \r\nSchedule to the Income Tax Ordinance, 2001 (XLIX of 2001) shall be amended \r\nthrough the insertion of the following sub-clause: \r\n“(47J)  For a period of 30 years from the mineral agreement effective date, the provisions \r\nof section 106A shall not apply in the case of Reko Diq Mining Company \r\n(Private) Limited. \r\nFor a period of 30 years from the mineral agreement effective date, no limit in \r\naddition to the thin capitalization under section 106 of the Income Tax Ordinance, \r\n2001 (XLIX of 2001) as at 20th March, 2022 shall apply in respect of \r\ndisallowance of profit on debt of the Reko Diq Project.” \r\n(8) Withholding tax on goods and services (time limited exemption and stabilization). \r\n(a)  Part IV of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of \r\n2001) shall be amended through the insertion of the following sub-clause: \r\n“(47K) The provisions of withholding taxes in sections 152, 153, 155 and 233 of the \r\nIncome Tax Ordinance, 2001 (XLIX of 2001) as well as any other withholding \r\ntaxes, shall not be applicable to Reko Diq Mining Company (Private) Limited as \r\na withholding agent during the period starting on the mineral agreement effective \r\ndate and ending on the 15th anniversary of such date.” \r\n(b)  Part III of the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of \r\n2001) shall be amended through the insertion of the following sub-clause: \r\n“(4) Following the 15th anniversary of the mineral agreement effective date, the Reko \r\nDiq Mining Company (Private) Limited shall, as a withholding agent, be subject \r\nto withholding tax on goods and services at the rates which were specified in the \r\nFirst Schedule to the Income Tax Ordinance, 2001 (XLIX of 2001) as at 20th \r\nMarch, 2022, unless any subsequent modified rates are reduced in which case \r\nsuch reduced rates shall apply to Reko Diq Mining Company (Private) Limited.” \r\n(9) Certain transaction taxes (exemption). The following clause shall be inserted in Part IV \r\nof the Second Schedule to the Income Tax Ordinance, 2001 (XLIX of 2001): \r\n“(47L) Notwithstanding any other provision of this Ordinance, for a period of time \r\ncommencing on the date this Act is enacted until 30 years from the mineral \r\nagreement effective date, (i) the provisions of sections 18, 37, 37A, 39, 101, 101A, \r\n108, 109, 114, 151 and 152 of this Ordinance shall not apply in relation to any of \r\nthe following transactions, and (ii) the provisions of clauses 47E, 47F and 145C \r\nof Part I of the Second Schedule to this Ordinance and sub-clause 21 of Part III \r\nof the Second Schedule to this Ordinance shall not apply in relation to any of the \r\nfollowing transactions but only to the extent that taxes (including local charges, \r\ncesses, duties, fees, levies or tolls) may be payable under clauses 47E, 47F and \r\n \r\nPage 20 of 29 \r\n \r\n145C of Part I of the Second Schedule to this Ordinance and sub-clause 21 of Part \r\nIII of the Second Schedule to this Ordinance: \r\n(a)  the allotment, issue, creation, direct or indirect transfer, bifurcation, division, sub-\r\ndivision, consolidation, redemption, conversion, reclassification, cancellation or \r\nother re-organisation of shares in Reko Diq Mining Company (Private) Limited \r\nor the transfer or grant of any direct or indirect interest in the Reko Diq Project, \r\nin each case where such action is taken, directly or indirectly, in connection with, \r\nor in contemplation of, the reconstitution and development of the Reko Diq \r\nProject or the transfer or grant of any direct or indirect interest in the Reko Diq \r\nProject to any entity majority owned or majority controlled by the Federal \r\nGovernment or the Provincial Government of Balochistan or any other transfer of \r\nshares of Reko Diq Mining Company (Private) Limited as contemplated in the \r\nagreements entered into in connection with the reconstitution of the Reko Diq \r\nProject; \r\n(b)  without limitation to sub-clause (a) above, the transfer of shares in Reko Diq \r\nMining Company Pakistan (Private) Limited by Tethyan Copper Company Pty \r\nLimited (a company incorporated in Australia) to any entity majority-owned or \r\nmajority-controlled by the Federal Government or the Provincial Government of \r\nBalochistan; \r\n(c)  the transfer of any direct or indirect interest in the Reko Diq Project, including \r\nshares and loans by Barrick Gold Corporation and its wholly-owned subsidiaries \r\nin connection with the exercise by the Federal Government or any purchaser \r\ndesignated by the Federal Government pursuant to the call option contained in the \r\njoint venture agreement governing the Reko Diq Project; \r\n(d)  the waiver, forgiveness or release by Tethyan Copper Company Pvt. Limited of \r\nany debt owed to it (or to any of its affiliates, associates, related parties, or direct \r\nor indirect shareholders) by Reko Diq Mining Company (Private) Limited; \r\n(e)  the receipt or transfer of any asset or payment or deemed payment (including \r\nmarkup, interest and penalty thereon) by or to Tethyan Copper Company Pvt. \r\nLimited or any of its affiliates, associates, related parties, direct or indirect \r\nshareholders, interest holders by whatever name called or any other person, which \r\nrelates directly or indirectly to the transactions in sub-clauses (a), (b), (c) and (d) \r\nabove, including distributions or share purchases by any of the entities mentioned \r\nin this sub-clause); and \r\n(f)  any action taken to resolve the outstanding disputes that relate to the Reko Diq \r\nProject and that involve Reko Diq Mining Company (Private) Limited or any of \r\nits affiliates, associates, related parties, or direct or indirect shareholders, \r\nincluding any formal waiver, surrender, disclaimer, release or discharge given by \r\nor on behalf of the Federal Government, the Provincial Government of \r\nBalochistan or any other person.” \r\n(47M) For a period of 30 years from the mineral agreement effective date, the provisions \r\nof section 100(3) shall not apply to Reko Diq Mining Company (Private) Limited. \r\n \r\n \r\nPage 21 of 29 \r\n \r\n(10) Advance tax on imports (exemption). The following shall be inserted in Part IV of the \r\nSecond Schedule to the Income tax Ordinance, 2001 (XLIX of 2001): \r\n“The provisions of section 148 shall not apply to Reko Diq Mining Company (Private) \r\nLimited for a period of 30 years from the mineral agreement effective date.” \r\n(11) Tax depreciation (stabilization). The Third Schedule to the Income Tax Ordinance, 2001 \r\n(XLIX of 2001) shall be amended through the insertion of the following: \r\n“PART IV \r\nFor a period of 30 years from the mineral agreement effective date, the rates of \r\ndepreciation, initial allowance and pre-commencement expenditure applicable to Reko \r\nDiq Mining Company (Private) Limited shall be the same as the rates which were \r\nspecified for the purposes of Section 22, Section 23 and Section 25 of the Income Tax \r\nOrdinance, 2001 on 20th March, 2022, unless any subsequent modified rates operate to \r\nthe advantage of Reko Diq Mining Company (Private) Limited in which case such more \r\nadvantageous rates shall apply to Reko Diq Mining Company (Private) Limited.” \r\n(12)  Anti-avoidance (exemption). Part IV to the Second Schedule to the Income Tax \r\nOrdinance, 2001 (XLIX of 2001) shall be amended through the insertion of the following \r\nsub-clause: \r\n“(125)  For a period of 30 years from the mineral agreement effective date, the \r\nprovisions of Chapter VIII - Anti-avoidance and any other anti-avoidance \r\nprovisions contained in any other legislation will not be applicable to any \r\nqualified investment as defined in the Foreign Investment (Promotion and \r\nProtection) Act, 2022.” \r\n         B.  Amendment to the Sales Tax Act, 1990 \r\n(1)  Pakistan Sales Tax on Goods (Zero Rating). The Fifth Schedule to the Sales Tax Act, \r\n1990 shall be amended through the insertion of the following clause: \r\n“(8A)  For a period of 30 years from the mineral agreement effective date [as defined in the \r\nIncome Tax Ordinance, 2001(XLIX of 2001)], imports or supplies made by, for or to \r\nReko Diq Mining Company (Private) Limited.” \r\nC. Amendment to the Privatization Commission Ordinance, 2000(LII of 2000). \r\n(1) Privatization Rules (Exemption).  Section 2(i) of the Privatization Commission \r\nOrdinance, 2000 (LII of 2000) shall be amended through the insertion of the following \r\nproviso: \r\n“Provided that no transaction will be considered a privatization if the value of \r\nthe transaction is less than the amount as may be prescribed by the Commission or if \r\nthe transaction has been exempted from the application of the Ordinance by the \r\nCommission.” \r\nD.  Amendment to the Companies Profits (Workers Participation) Act, 1968 (XII of \r\n1968).—The Companies Profits (Workers Participation) Act, 1968 (XII of 1968) shall be \r\namended through the insertion of the following section: \r\n \r\nPage 22 of 29 \r\n \r\n“8A.  Power to exempt.— The Federal Government may, through notification in the official \r\nGazette,— \r\n(a)  declare that any company or class of companies shall be exempt from the \r\napplication of the scheme; and \r\n(b) exempt any company or class of companies from any amount payable under \r\nsection 3 of this Act.” \r\nE. Amendment to the Workers Welfare Fund Ordinance, 1971 (XXXVI of 1971).— The \r\nWorkers Welfare Fund Ordinance, 1971 (XXXVI of 1971) shall be amended through the \r\ninsertion of the following section: \r\n“16A.   Power to exempt.— The Federal Government may, through notification in the \r\nofficial Gazette, exempt any industrial establishment from any provision of this \r\nAct.” \r\nF. Amendment to the Customs Act, 1969 (IV of 1969).— \r\n(1) Section 18(1A) of the Customs Act, 1969 (IV of 1969) shall be amended to read as \r\nfollows: \r\n“(1A)  Notwithstanding anything contained in this section or in section 18A, customs \r\nduties (including regulatory duties, additional customs duties, special customs \r\nduties as well as any other taxes or duties levied under this Act) shall be levied \r\nat such rates on the import of goods or class of goods (including the import of \r\ngoods or a class of goods by specified persons or classes of persons) as are \r\nprescribed in the Fifth Schedule, subject to such conditions, limitations and \r\nrestrictions as prescribed therein.” \r\n(2)  The Fifth Schedule to the Customs Act, 1969 (IV of 1969) shall be amended through \r\nthe addition of a new Part-VIII as follows: \r\nPart-VII \r\nImports by and for the benefit of the Reko Diq Mining Company (Private) Limited, its \r\ncontractors and its employees. \r\nS. \r\nNo. \r\nDescription of \r\nGoods PCT Code \r\nCustoms \r\nDuty, \r\nRegulatory \r\nDuty, \r\nAdditional \r\nCustoms \r\nDuty, any \r\nother taxes or \r\nduties under \r\nthe Customs \r\nAct,1969 \r\nSpecial Conditions \r\n1. all goods: \r\n \r\n(a) exported or \r\nproduced by the \r\nReko Diq Mining \r\nRespective \r\nheadings \r\n0%,0%,0%,0% (1) the imported goods as are not \r\nlisted in the locally manufactured \r\nitems, notified through a Customs \r\nGeneral Order issued by the Federal \r\nBoard of Revenue (FBR)  from time \r\n \r\nPage 23 of 29 \r\n \r\nCompany (Private) \r\nLimited, or; \r\n \r\n(b) import ed by the \r\nReko Diq Mining \r\nCompany  (Private) \r\nLimited; or \r\n \r\n(c) imported for the \r\nbenefit of the Reko \r\nDiq Mining \r\nCompany (Private) \r\nLimited by any \r\ncontractors or sub -\r\ncontractors of the \r\nReko Diq Mining \r\nCompany (Private) \r\nLimited, or other \r\nrelated third parties  \r\n \r\nExplanation: Goods \r\nshall include, but not \r\nbe limited to plant, \r\nequipment, \r\nmachinery \r\n(including vehicles), \r\nspare parts, and \r\ncomponents \r\n \r\nto time or, as the case may be, \r\ncertified as such by th e Engineering \r\nDevelopment Board: \r\n \r\n(2) in case of partial shipments of \r\nmachinery and equipment for setting \r\nup a plant,  the importer shall, at the \r\ntime of arrival of first partial \r\nshipment, fumish complete details of \r\nthe machinery, equipment and \r\ncomponents required for the \r\ncomplete plant, duly supported by the \r\ncontract, lay out plan and drawings; \r\nand \r\n \r\n(3) An authoris ed representative \r\nof the Reko Diq Mining Company \r\n(Private) Limited shall certify in the \r\nprescribed manner and format as per \r\nAnnex-A that the imported items are \r\nthe company’s bona fide requirement. \r\nHe shall furnish all relevant \r\ninformation online to Pakistan \r\nCustoms Computerized System \r\nagainst a specific user ID and \r\npassword obtained under section \r\n155D of the Customs Act, 1969 (IV \r\nof  1969). In already computerized  \r\nCollectorates or Customs stations \r\nwhere the Pakistan Customs \r\nComputerized System is not \r\noperational, the Director Reforms and \r\nAutomation or any other person \r\nauthorized by the Collector in this \r\nbehalf shall enter the requisite \r\ninformation in the Pakistan Customs \r\nComputerized System on daily basis, \r\nwhereas entry of the data obtained \r\nfrom the customs stations which have \r\nnot yet been computerized shall be \r\nmade on weekly basis. \r\n2. Household go ods of \r\nemployees of the \r\nReko Diq Mining \r\nCompany  \r\n(Private) Limited  \r\nRespective \r\nheadings \r\n0%,0%,0%,0% Only such employees can claim this \r\nbenefit who are either citizens of  a \r\ncountry other than Pakistan or who , \r\nfor the Tax Year immediately prior to \r\nthe import of goods, were non -\r\nresident in Pakistan for the purposes \r\nof the Income Tax Ordinance, 2001. \r\n \r\nG. Sindh Companies Profits (Worker's Participation) Act, 2015 (Sindh Act No. XVIII of \r\n2016). \r\nArticle 1 of the Schedule to the Sindh Companies Profits (Worker's Participation) Act, 2015 \r\n(Sindh Act No. XVIII of 2016) shall be amended through the insertion of the following proviso: \r\n \r\nPage 24 of 29 \r\n \r\n“Provided that the scheme shall not apply to Reko Diq Mining Company (Private) \r\nLimited for a period of 30 years from the mineral agreement effective date [as defined in the \r\nIncome Tax Ordinance, 2001 (XLIX of 2001)].” \r\nH. Sindh Workers Welfare Fund Act, 2014 (Sindh Act No. XXXIII of 2015). \r\nSection 15 of the Sindh Workers Welfare Fund Act, 2014 (Sindh Act No. XXXIII of 2015) \r\nshall be amended to read as follows: \r\n“The Government may, by notification in the official Gazette, remit or reduce the amount due \r\nfrom any industrial establishment or class of industrial establishments under any provision of \r\nthis Act: \r\nProvided that two percent contribution under section 5 and the additional contribution \r\nunder section 6 due from any class of industrial establishment may also be remitted or reduced \r\nby Government at its discretion on the merits of each case.” \r\nI. Sindh Development and Maintenance of Infrastructure Cess Act, 2017 (Sindh Act No. \r\nXVIII of 2017). \r\nThe proviso to section 6 of the Sindh Development and Maintenance of Infrastructure Cess \r\nAct, 2017 (Sindh Act No. XVIII of 2017) shall be amended through the addition of the words \r\n“any person or class of persons” so that it reads as follows: \r\n“Notwithstanding anything contained in section 3 and 5, the Government by a notification in \r\nthe official Gazette, for reasons to be recorded, may exempt any goods or category or class of \r\ngoods or any person or class of persons from payment of whole or any part of the cess payable \r\nunder the Act subject to such conditions and limitations as may be specified in such \r\nnotification.” \r\nJ. Balochistan Development and Maintenance of Infrastructure Cess Act, 2021 (IX of \r\n2021). \r\nThe proviso to Section 6 of the Balochistan Development and Maintenance of Infrastructure \r\nCess Act, 2021 (IX of 2021) shall be amended through the addition of the words “any person \r\nor class of persons” so that it reads as follows: \r\n“Notwithstanding anything contained in section 3 and 5, the Government by a notification in \r\nthe official Gazette, for reasons to be recorded, may exempt any goods or category or class of \r\ngoods or any person or class of persons from payment of whole or any part of the cess payable \r\nunder the Act subject to such conditions and limitations as may be specified in such \r\nnotification.” \r\nK. Balochistan Workers Welfare Fund Act, 2022 (XXI of 2022). \r\nSection 19 of the Balochistan Workers Welfare Fund Act, 2022 (XXI of 2022) shall be \r\namended through the insertion of the following sub-section: \r\n“(3) The Provincial Government may, through notification in the official Gazette, exempt \r\nany industrial establishment from any provision of this Act.” \r\n \r\n \r\nPage 25 of 29 \r\n \r\nL. Balochistan Excise Duty on Minerals (Labour Welfare) Act, 1967 (VIII of 1967). \r\nThe proviso to Section 3 of the Balochistan Excise Duty on Minerals (Labour Welfare) Act, \r\n1967 (VIII of 1967) shall be amended to read as follows: \r\n“Provided that the Government may, by notification in the official Gazette, exempt \r\nfrom liability to the duty any of such minerals or any class thereof and may also exempt from \r\nliability to the duty, any person or class of persons.” \r\nM. Federal Excise Act, 2005. \r\nThe Third Schedule to the Federal Excise Act, 2005 shall be amended to include the following \r\nentries: \r\n“Table I \r\nFor a period of 30 years from the Mineral Agreement Effective Date (as defined in the Income \r\nTax Ordinance, 2001), import or supplies of goods made by, for or to Reko Diq Mining \r\nCompany (Private) Limited. \r\n \r\nTable II \r\nFor a period of 30 years from the mineral agreement effective date [as defined in the Income \r\nTax Ordinance, 2001 (XLIX of 2001)], services provided to Reko Diq Mining Company \r\n(Private) Limited.” \r\nTHIRD SCHEDULE  \r\nPROTECTED BENEFITS \r\nThe following Investment Incentives are hereby declared to be Protected Benefits: \r\n1. For a period of 30 years from the Mineral Agreement Effective Date (as defined in the \r\nIncome Tax Ordinance, 2001) in relation to the Reko Diq Project (as defined in the Income \r\nTax Ordinance, 2001 for purposes of this Third Schedule): \r\n(a) SRO 2194(I)/2022 dated 12th December, 2022 issued by the Ministry of \r\nIndustries and Production declaring (i) the entire area of the Reko Diq Project, \r\nincluding all roads, pipelines, power generation facilities, transmission lines, \r\nprocessing facilities and any other infrastructure used in or in connection with \r\nthe Reko Diq Project operations, and all lands and orebodies, including Tanjeel, \r\nthat lie within the mining lease areas granted to Reko Diq Mining Company \r\n(Private) Limited (as defined in the Income Tax Ordinance, 2001, and referred \r\nto in this Third Schedule as “RDMC”), together with the lands covered by the \r\nexploration license and surface lease granted to RDMC, (ii) the offices of \r\nRDMC located in Quetta and/or Karachi, and (iii) any bank branches of \r\ninternational or local banking institutions that are located at the same building(s) \r\nas the offices of RDMC located in Quetta and/or Karachi, as the Export \r\nProcessing Zone in respect of the Reko Diq Project. \r\n \r\nPage 26 of 29 \r\n \r\n(b)  SRO 881(I)/80 dated 23-8-1980 issued by the Ministry of Finance and \r\nEconomic Coordination, Government of Pakistan (Exemption from Import/ \r\nExport Customs Duties for Export Processing Zones). \r\n(c) SRO 882(I)/80 dated 23-8-1980 issued by the Ministry of Finance and \r\nEconomic Coordination, Government of Pakistan (Authorization of Repayment \r\nof Customs Duties and Sales Tax Paid on Raw Materials Used in the \r\nManufacture of Goods Admitted into an Export Processing Zone). \r\n(d)  SRO 1248(I)/81 dated 23-11-1980 issued by the Ministry of Industries, \r\nGovernment of Pakistan (Exemption from Applicability of the Foreign \r\nExchange Regulations Act, 1947 and the Banking Companies Ordinance, 1962 \r\nto an Export Processing Zone). \r\n(e) SRO 1332(1)/81 dated 13-12-1981 issued by the Ministry of Industries, \r\nGovernment of Pakistan (Exemption of Export Processing Zones from Foreign \r\nExchange Regulations Act, 1947). \r\n(f)  SRO 535(I)/80 dated 15-5-1980 issued by the Ministry of Finance, Planning and \r\nProvincial Coordination, Government of Pakistan (EPZ exemption relating to \r\nexports). \r\n(g) SRO 436(I)/80 dated 25-5-1980 issued by the Ministry of Finance, Planning and \r\nProvincial Coordination, Government of Pakistan (EPZ exemption). \r\n(h)  SRO 858(1)/82 dated 8-9-1982 issued by the Federal Government (Exemption \r\nof the Export Processing Zones from the Insurance Act, 1938 (IV of 1938) and \r\nPakistan Insurance Corporation Act, 1957 (XXXVII of 1952). \r\n(i)  SRO 1022(I)/92 dated 18-10-1992 issued by the Central Board of Revenue \r\n(Exemption from central excise duty on such goods manufactured in the Tariff \r\nArea of Pakistan as are imported into an Export Processing Zone for use as raw \r\nmaterials or intermediary goods for further manufacture of goods in the Zone \r\nfor export). \r\n(j)  SRO 1004(I)/82, dated 10-10-1982 issued by the Ministry of Industries \r\n(Exemption of Export Processing Zones from various labour laws). \r\n(k)  SRO 2195(I)/2022 dated 12th December, 2022 issued by the Ministry of \r\nIndustries and Production under section 25 of Export Processing Zones \r\nAuthority Ordinance, 1980 and under section 26 of the Export Processing Zones \r\nAuthority Ordinance, I980 modifying rule 16 of the Export Processing Zone \r\nAuthority Rules, 1981 (Stabilization of rate and basis of calculation of EPZ \r\nProcessing Surcharge). \r\n(l)  SRO 154/2022 dated 12th December 2022 issued under section 6 read with \r\nsection 16 of the Balochistan Development and Maintenance of Infrastructure \r\nCess Act, 2021 (Act No. IX of 2021) by the Finance Department, Government \r\nof Balochistan (Exemption from import and export taxes in Balochistan \r\nProvince). \r\n \r\nPage 27 of 29 \r\n \r\n(m) SRO SO(TAXES)ET&NC/2(204)/2015 dated 13th December 2022 issued \r\nunder section 6 of the Sindh Development and Maintenance of Infrastructure \r\nCess Act, 2017 (Act No. XVIII of 2017) by the Excise and Taxation \r\nDepartment, Government of Sindh (Exemption from import and export taxes in \r\nSindh Province). \r\n(n)  SRO 2196(I)/2022 dated 12th December, 2022 issued under section 16A of the \r\nWWF Ordinance, 1971 by the Ministry of Overseas Pakistanis and Human \r\nResource Development, Government of Pakistan (Exemption from requirement \r\nto make WWF contributions). \r\n(o) SRO 155/2022 dated 12th December, 2022 issued under section 11 of the \r\nBalochistan Companies Profits (Workers Participation) Act, 2022 by the \r\nDepartment of Labour and Manpower, Government of Balochistan (Exemption \r\nfrom tax under WPPF). \r\n(p)  SRO 151/2022 dated 12th December, 2022 issued under section 3 of the \r\nBalochistan Excise Duty on Minerals (Labour Welfare) Act, 1967 by the \r\nDepartment of Mines and Minerals, Government of Balochistan (Exemption \r\nfrom certain Provincial labour taxes). \r\n(q) SRO 156/2022 dated 12th December, 2022 issued under section 19(3) of the \r\nBalochistan Workers Welfare Fund Act, 2022, as amended, by the Department \r\nof Labour and Manpower, Government of Balochistan, (Exemption from \r\nprovincial WWF). \r\n(r)  SRO 2199(I)/2022 dated 12th December, 2022 issued under section 3(1) of the \r\nForeigners Act, 1946, by the Ministry of Interior, Government of Pakistan (Fly-\r\nin fly-out activities). \r\n(s)  SRO 157/2022 dated 12th December, 2022 issued under section 9(1)(a) of the \r\nStamp Act, 1899, by the Board of Revenue, Government of Balochistan \r\n(Remission from stamp duties). \r\n(t)  SRO 158/2022 dated 12th December, 2022 issued under section 78 of the \r\nRegistration Act, 1908, by the Board of Revenue, Government of Balochistan \r\n(Exemption from registration fees on Mineral Agreement and Joint Venture \r\nAgreement). \r\n(u)  SRO(II)21-25/2015 dated 13th December 2022 issued under section 15 of the \r\nSindh Workers Welfare Fund Act, 2014 by the Department of Labour, \r\nGovernment of Sindh (Exemption from provincial WWF). \r\n(v)  SRO SECY(RS&EP)BOR/2022-278 dated 12th December 2022 issued under \r\nsection 9(1)(a) of the Stamp Act, 1899, by the Board of Revenue, Government \r\nof Sindh (Remission from stamp duties). \r\n(w) SRO 152/2022 dated 12th December, 2022 issued under section 7 of the \r\nRegulation of Mines and Oilfields and Mineral Development (Government \r\nControl) Act, 1948 by the Department of Mines and Mineral Development, \r\nGovernment of Balochistan (Stabilization of Agreed Balochistan Royalty). \r\n \r\nPage 28 of 29 \r\n \r\n(x)  SRO 2200(I)/2022 dated 12th December, 2022 issued under section 8(12) of the \r\nFinance Act, 2022 by the Revenue Division, Government of Pakistan \r\n(Exemption from capital value tax). \r\n2. For a period of 10 years from the Commercial Production Date (as defined in the Income \r\nTax Ordinance, 2001) in relation to the Reko Diq Project: \r\n(a) SRO 153/2022 dated 12th December, 2022 issued under section 12 of the \r\nBalochistan Sales Tax on Services Act, 2015 by the Finance Department, \r\nGovernment of Balochistan (Time limited exemption and rate stabilization). \r\n(b)  SRO SRB-3-4/47/2022 dated 12th December, 2022 issued under section 10 of \r\nthe Sales Tax on Services Act, 2011 by the Finance Department, Government \r\nof Sindh (Time limited exemption and rate stabilization). \r\n3. For a period of I5 years from the Commercial Production Date (as defined in the Income \r\nTax Ordinance, 2001) in relation to the Reko Diq Project: \r\n(a) SRO 2197(I)/2022 dated 12th December, 2022 issued under section 8A of the \r\nCompanies Profits (Workers Participation) Act, 1968 by the Ministry of \r\nOverseas Pakistanis and Human Resource Development, Government of \r\nPakistan (Time limited exemption and rate stabilization of WPPF \r\ncontributions). \r\n4.  For a period of 3 years from the Mineral Agreement Effective Date (as defined in the Income \r\nTax Ordinance, 2001) in relation to the Reko Diq Project: \r\n(a)  SRO 2198(I)/2022 dated 12th December, 2022 issued under section 9 of the \r\nStamp Act, 1899 by the Ministry of Interior, Government of Pakistan \r\n(Remission from stamp duty payable on share transfers). \r\n5. For a period of 30 years from the Mineral Agreement Effective Date (as defined in the \r\nIncome Tax Ordinance, 2001), the following Investment Incentives are hereby declared as \r\nProtected Benefits in relation to, and for the benefit of, the Reko Diq Project: \r\n(a)  The Reko Diq Project and each of its Investors have permission to freely and \r\nwithout restriction open, maintain and operate (A) foreign currency accounts \r\noutside Pakistan and (B) foreign currency accounts within Pakistan to the extent \r\nthese accounts are located in an Export Processing Zone and relate to the Reko \r\nDiq Project. Such accounts held by RDMC, each of its direct subsidiaries or \r\nother Investors that are not Enterprises established under the laws of Pakistan \r\nshall constitute protected accounts for purposes of this Act; \r\n(b)  The Reko Diq Project and each of its Investors also shall have permission to \r\nopen, maintain and operate local currency accounts within Pakistan in \r\naccordance with applicable banking and foreign exchange laws and regulations, \r\napplied on a non-discriminatory basis; \r\n(c) The Reko Diq Project and each of its Investors have permission to freely and \r\nwithout restriction, bring, hold, retain off-shore, buy, sell, transfer, expatriate \r\nand take out foreign currency from or to the accounts referred to in sub-clause \r\n \r\nPage 29 of 29 \r\n \r\n5(a) above, in any form without delay and without any requirement to make a \r\nforeign exchange declaration at any stage or to satisfy any other requirement, to \r\nmeet the requirements of Investors, lenders, contractors, operators, consultants, \r\ninsurers, reinsurers, vendors, contract counterparties and advisors in relation to \r\nany compensation amounts, payments, loan repayments (including interest), \r\nequity and return on equity, returns of capital, profits, works, goods and \r\nservices; \r\n(d) RDMC and each of its direct subsidiaries shall have access to non- \r\ndiscriminatory rates for foreign exchange transactions; and \r\n(e)  The State Bank of Pakistan and other financial institutions within Pakistan shall \r\nnot impose any restrictions on deposits in or withdrawals from any bank to bank \r\ntransactions from the protected accounts held by a foreign Investor in an Export \r\nProcessing Zone in respect of the Reko Diq Project.",
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