IWhen clients call
Services / 03 — Tax & regulatory
A position we could still defend in three years.
Income tax, sales tax across federal and provincial authorities, withholding, notices, assessments, appeals and transfer pricing — for businesses in Pakistan and groups operating across borders.
Anyone can file a return. The question is whether the position behind it survives an assessment, an audit selection or an appeal years later — and whether the deadline was ever in doubt. That is what we are actually selling.
Received an FBR notice?
The clock starts when the notice is served, not when someone gets round to reading it. Send it to us and a partner will tell you what it is, what it is asking for, and what the response needs to contain.
A notice has arrived and nobody knows what it means.
We identify the provision it is issued under, what is actually being asked, and what a defensible response contains.
We have been selected for audit.
Audit selection is not an accusation. It is a process with a documentary standard, and files that meet it close quickly.
Our refund has been sitting with the department for months.
Refund claims usually stall on documentation rather than on merit. We identify what is missing and pursue it.
We operate in three provinces and each one wants sales tax.
Where a service is rendered, and therefore which authority taxes it, is the most common structural exposure we see.
Our withholding statements are behind.
Withholding defaults compound quietly and become a recovery action against the withholding agent, not the payee.
We pay a related party overseas and have no documentation.
Transfer pricing documentation is prepared before it is asked for, or it is prepared under pressure and disbelieved.
We are being acquired and the buyer is asking about tax exposure.
Undocumented positions become priced deductions in diligence. We quantify and, where possible, close them first.
We are setting up in Pakistan and do not know what we owe.
Registration, withholding obligations, filing calendar and provincial exposure, established before the first transaction rather than after it.
IIWhat we do
Scope of the tax practice
Led by our Executive Director — Taxation, with more than ten years of FBR practice behind it.
01
Income tax compliance
Registration through to filing, for companies, AOPs, individuals and non-residents.
- NTN registration and IRIS enrolment
- Annual income tax returns
- Wealth statements and reconciliation
- Advance tax computation and instalments
- Minimum and alternative corporate tax positions
- Group and holding company positions
02
Sales tax — federal and provincial
The area where multi-province businesses carry the most undocumented exposure.
- STRN registration with FBR and provincial authorities
- Monthly returns across jurisdictions
- Input tax apportionment and adjustment
- Place-of-supply and jurisdiction analysis for services
- Exemption and reduced-rate positions
- Sales tax audits and reconciliations
03
Withholding tax
The obligation that falls on the payer, and the one most frequently found in default.
- Withholding agent obligations mapping
- Quarterly and annual withholding statements (Section 165)
- Rate determination by payment type and filer status
- Exemption and lower-rate certificates
- Reconciliation to financial statements
- Default remediation and disclosure
04
Notices, assessments and appeals
Representation from the first notice through to the appellate forums.
- Notice review and response drafting
- Audit selection and audit proceedings
- Amendment of assessment proceedings
- Representation before the Commissioner
- Appeals to the Commissioner (Appeals) and Appellate Tribunal
- Recovery, attachment and stay matters
05
Transfer pricing
Documentation prepared before it is requested, which is the only version that persuades.
- Related-party transaction mapping
- Functional and comparability analysis
- Local file documentation
- Intercompany agreements review
- Pakistan–Gulf related-party flows
- Support during transfer pricing scrutiny
06
Refunds and recoveries
Most refund claims stall on evidence rather than entitlement.
- Refund claim preparation and filing
- Documentation assembly and gap closure
- Follow-up and departmental liaison
- Sales tax refund verification
- Excess withholding recovery
07
Tax planning and structuring
Lawful positions we would defend, not aggressive ones we would have to.
- Entity and group structure review
- Remuneration and payroll structuring
- Treaty positions for cross-border payments
- Repatriation and dividend planning
- Restructuring and reorganisation tax effects
08
Non-resident and cross-border
For foreign companies operating in Pakistan and Pakistani groups operating abroad.
- Permanent establishment analysis
- Branch and liaison office taxation
- Double taxation treaty relief
- Withholding on payments to non-residents
- Foreign branch registration support with SECP and BOI
IIINotices
What the notice actually is
Most notices are procedural. A few are serious. Knowing which is which on the day it arrives is most of the value.
| Type of notice | What it usually means, and what it needs |
|---|---|
| Request for information — e.g. Section 176, Income Tax Ordinance 2001 | The department wants documents or explanations. Usually routine. It becomes serious when ignored, because non-response is itself a basis for adverse action. |
| Notice to file a return — e.g. Section 114, Income Tax Ordinance 2001 | A return the department believes is due has not been filed. Establish first whether the obligation actually exists — sometimes it does not. |
| Audit selection — e.g. Section 177, Income Tax Ordinance 2001 | Your return has been selected for audit. Not an accusation, and not negotiable. It is a documentary process, and a file that meets the standard closes quickly. |
| Amendment of assessment — e.g. Section 122, Income Tax Ordinance 2001 | The department proposes to change your assessed position. This is where the substantive argument happens and where documentation decides the outcome. |
| Withholding default — e.g. Section 161, Income Tax Ordinance 2001 | Alleged failure to deduct or deposit tax. The liability falls on the withholding agent — you — regardless of whether the payee has paid. |
| Penalty and default surcharge — e.g. Sections 182 and 205, Income Tax Ordinance 2001 | Consequential on another finding. Often reducible where the underlying position is defended or reasonable cause is established. |
| Recovery proceedings — e.g. Section 138, Income Tax Ordinance 2001 | Attachment of bank accounts or receivables. Urgent. Stay and rectification routes exist but are time-bound. |
Section references are illustrative and may be renumbered or amended by a Finance Act — always confirm the applicable provision at the time.
IVHow we work on tax
Four things we do differently
01
Every position is reviewed before filing
A second qualified professional reviews the technical position before anything is submitted. Not a spellcheck — a challenge to the reasoning, on the assumption it will be challenged again later by someone less friendly.
02
Positions are documented against the provision relied on
Written down at the time, referenced to the statutory basis. Three years later, when the notice arrives and the person who prepared it has left, the reasoning is still on the file.
03
Deadlines live on a calendar, not in someone's head
Filing obligations are tracked per client centrally. Correspondence from any authority is logged on receipt with the response date fixed from day one.
04
We do not take positions we would not defend
An aggressive filing that generates a notice, a penalty and three years of appeals has not saved anybody money. If you want a position we think will fail, we will tell you — and we will tell you why before you decide.
These are the firm's controls applied to tax work specifically. The full set, applied to every engagement of any type, is published.
VICommon questions
Questions we are asked
I have received an FBR notice. What should I do first?
Read what provision it is issued under and what date it was served — the response period runs from service, not from when you opened it. Do not respond partially or informally; an incomplete reply becomes part of the record. Send us the notice and we will tell you what it is, what it is actually asking for and what a defensible response contains.
What happens if I ignore a tax notice?
Non-response is itself a basis for adverse action. The department can proceed to an ex parte assessment on the information it holds, which is almost always worse than the position you could have established, and penalties and default surcharge follow. Reversing it afterwards costs considerably more than answering would have.
Why do I have to register for sales tax in more than one province?
Sales tax on services is a provincial subject in Pakistan. Punjab, Sindh, Khyber Pakhtunkhwa and Balochistan each have their own authority, their own rates and their own view of where a service is rendered. A business serving clients in multiple provinces frequently has obligations in each, and the jurisdictions do not always agree on which of them is owed the tax.
How long does an FBR refund take?
It depends far more on documentation than on the department. Claims stall where supporting evidence is incomplete or inconsistent with the return, and each cycle of queries adds months. A claim assembled correctly before filing moves considerably faster than one corrected afterwards.
Do we need transfer pricing documentation?
If you transact with related parties — particularly cross-border — then documentation supporting the pricing is expected, and the time to prepare it is before it is requested. Documentation produced after a query begins is both harder to assemble and less persuasive.
Can you take over our tax compliance from another adviser?
Yes. We would begin by reviewing the current filing position and the last few years of returns, because the exposure we inherit matters more than the work going forward. Where we find something, you will hear it early rather than at the first notice.
Do you handle tax for foreign companies operating in Pakistan?
Yes — including permanent establishment analysis, branch taxation, treaty relief, withholding on payments to non-residents, and registration support with SECP and the Board of Investment. Foreign branches of state-owned construction groups are among our longest-standing clients.
How are tax engagements priced?
Compliance work — registrations, returns, withholding statements — is normally a fixed fee. Notice response, assessment and appeal work is time-based with an agreed range and a cap we will not exceed without discussing it with you first.
Related
Where tax work usually leads
Let's work together
Send us the notice, or the question.
A partner will tell you what you are dealing with and what it will take — before you commit to anything.