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CFAP – 05
Advanced Taxation
[Trainer: Fawad Hassan – ACA]
2
Dos and Don’ts
1. Referring too many books
2. Optimize Memory Utilization
3. Improvise Retrieval Ability
4. First understand “The Big Picture” – Taxation Framework/Mechanism
5. Then “Zoom In” for details
3
Expectations
1. Understanding of Taxation Laws
2. Application of Understanding
4
Syllabus
Grid Weighting Last 8 years’ Average
Income Tax 50-55 59
Sales Tax 30-35 28
Faderal Excise Law 10-15 12
Professional values, ethics and attitude 5-10 1
Details
5
Revenue Collection
Exchequer
(FederalConsolidatedFund)
Inflows
Outflows
Income Tax
CVT
WWF
Sales Tax
FED
Custom Duty
DeficitLoans & Grants
Capital Receipts
Revenue
Receipts
Non Tax Receipts
Tax
Receipts
Other Taxes
FBR
Taxes
Indirect
Tax
Direct Tax
External Receipts
Internal
Receipts
6
Income Tax
6 Basic Questions
1. Tax Year
2. Type of Person
3. Residential Status
4. Tax Regime
5. Geographical Source of Income
6. Apportionment of Deductions
7
1. Tax Year [S-74]
Time Bracket
Normal Tax Year
(NTY)
End date is other
than 30th June
End date is 30th
June
Time period of
less than 12
months
Time period of 12 months
Transitional Tax
Year (TTY)
Special Tax Year (STY)
Denoted by Calendar Year
relevant to NTY in which
Year end falls
Denoted by Calendar
Year in which NTY ends
Denoted by Calendar
Year relevant to NTY in
which Year end falls
FBR has authority to
prescribe STY
TTY occurs because of
change in TY from NTY to
STY or vice versa
TTY is the period between TY end date of last tax year and commencement date of next TY
Industry Special Tax Year SRO Ref
Sugar Manufacturing 1st October - 30th September 134(R)/68,
July 31,1968
Rice Exporter 1st January - 31st December 367(I) /74,
January 14,1974
Insurance 1st January - 31st December 878 (I) /95,
August 30,1995
8
Change in Tax Year
NTY STY STY - 1 STY - 2STY NTY
Tax Payer will give an application in writing to Commissioner of Income Tax (CIT)
CIT is convinced that
compelling need
exists
Not Convinced
Give tax payer an opportunity
of being heard in person
Not Convinced
1) issue rejection orders
2) record reasons of rejection
in order
Tax Payer may file review application to FBR & decision of FBR shall be final
Grant Permission through an
order in writing
9
Tax Year Practice
Determine the tax year in respect of each accounting periods mentioned below:
a) 1.09.2015 to 31.08.2016
b) 01.04.2016 to 30.06.2016
c) 1.01.2016 to 31.12.2016
d) 1.04.2016 to 31.03.2017
e) 1.05.2016 to 30.04.2017
f) 1.07.2016 to 30.06.2017
STY
TTY
STY
STY
STY
NTY
TY 2017
TY 2016
TY 2017
TY 2017
TY 2017
TY 2017
10
2. Type of Person
a) Tax Payer [S-2(66)]
b) Person [S-80]
11
a) Tax Payer [S-2(66)]
Any person or representative of person who;
i. Derives an amount chargeable to tax
ii. Is required to collect/deduct tax
iii. is required to furnish return of income
iv. is required to pay tax
under Income Tax Ordinance 2001
12
b) Person [S-80]
Following shall be treated as person;
i. Individual
ii. Company formed in Pakistan or elsewhere
iii. AOP formed in Pakistan or elsewhere
iv. Federal government
v. Foreign government
vi. Political subdivision of foreign government
vii. Public International Organization
13
Company means following
i. Company as defined in Companies Ordinance 1984
ii. Body Corporate formed by or under any law in force in Pakistan
iii. Modaraba
iv. body incorporated by or under any law of country outside Pakistan relating to
incorporation of companies
v. cooperative society, finance society or any other society
vi. non-profit organization
vii. Trust
viii. foreign association declared by FBR to be a company
ix. Provincial Government
x. Local Government
xi. Small company as defined in Section -2
14
Association of Persons includes following
i. Firm (means relation between persons who have agreed to share profits of business
carried on by all or any one of them acting for all)
ii. Hindu Undivided Family
iii. Artificial Juridical Person
iv. Any body of persons formed under foreign law
And does not include “Company”
15
3. Residential Status
a) Resident Individual
b) Resident Company
c) Resident AOP
16
a) Resident Individual [S-82]
i. Not based on Nationality
ii. Based on Physical Presence in Pakistan
iii. Government servant posted abroad will be treated as resident, irrespective of his
physical stay in Pakistan
iv. Counting of days shall be made in accordance with Rule-14 of Income Tax Rules,
2002
0 – 182 days 183 days or more
Non Resident Resident
17
Rule-14 of Income Tax Rules, 2002
Days not to be counted Days to be counted
i. Day or part of day in Pakistan solely
by reason of being in transit between
two different places outside Pakistan
Part of a day shall be counted as a whole
day in following cases;
i. Day of arrival in Pakistan
ii. Day of departure from Pakistan
iii. Public Holiday
iv. Leave, including sick leave
v. Holiday spent in Pakistan before,
during or after activity in Pakistan
vi. Day when activity was interrupted
due to Strike, lockout, delay in
receipt of supplies
18
b) Resident Company [S-83]
i. Company incorporated in Pakistan
ii. Provincial Government
iii. Local Government
iv. Company incorporated outside Pakistan
Resident
No further condition required
Resident
if, Control and Management of
affairs situated wholly in
Pakistan at any time in a Tax
Year
19
b) Resident AOP [S-84]
Resident if, Control and Management of affairs situated wholly or partly in Pakistan at
any time in a Tax Year
20
Residential Status Practice
i. Mr. Raza is working as Director Operations in the Ministry of Tourism. On 15 July 2016 he was posted to Pakistan Embassy in
Italy for two years.
ii. Anderson LLC was incorporated as limited liability Company in UK. The control and management of its affairs was situated
wholly in Pakistan. However, with effect from 01 November 2016, the entire management and control was shifted to UK.
iii. On 01 February 2017, Mr. Sameel was sent to Pakistan by his UK based company to work on a special project. He left Pakistan
on 23 August 2017.
iv. BBL is a non-listed public company incorporated under the Companies Ordinance, 1984. All the shareholders of the company
are individuals. The control and management of affairs of the company during the year was outside Pakistan.
v. Mr. Salman a property dealer in USA came to Pakistan on 01 February 2016. During his stay upto 02 August 2016 in Pakistan,
he remained in Peshawar upto 30 June 2016 and thereafter till his departure from Pakistan, in Quetta. Assume that
Commissioner has granted him permission to use calendar year as special tax year.
vi. Peshawar LLC (PLLC) was incorporated as a limited liability company in UAE. PLLC has 5 directors out of which 2 are involved
in management, the rest of them were situated in UAE. The 2 directors control the affairs of the company from Pakistan.
Resident
Resident
Non
Resident
Resident
Resident
Resident
Federal Govt Employee
Control & Mngt in wholly in
Pak any time in TY
Stay less than 180 days
Company incorporated in
Pak
Total stay 184 days
Control & Mngt in wholly in
Pak any time in TY
21
4. Tax Regimes
Heads of Income
Salary Income
Property Income
Business Income
Capital Gains
Income from Other Sources
Total Income
- Deductible Allowances
Taxable Income
Rate from 1st Schedule
Tax Imposed/Chargeable
- Tax Credits
Tax Payable
- Withholding Tax/Adv Tax
Income Tax Demand/Refund
Normal Tax Reg. Separate Block Final Tax Reg Minimum Tax Reg
10
10
10
10
10
10%
50
(2)
(10)
1
40
4
(1)
3
22
5. Geographical Source of Income
a) Pakistan Source Income [S-2(40) & 101]
b) Foreign Source Income [S-2(27) & 101(16)]
Resident Non Resident
Pakistan Source Income Taxable Taxable
Foreign Source Income Taxable Not Taxable
23
6. Apportionment of Deductions [S-67 & Rule 13]
Apportionment of Deductions [S-67]
Any expenditure/deduction/allowance that relates with following shall be
apportioned on reasonable basis:
a) derivation of income under more than one head of income
b) derivation of taxable income and income under Final Tax Regime
c) derivation of income under any head of income and for any other purpose
24
6. Apportionment of Deductions [S-67 & Rule 13]
Apportionment of Expenditures Deductions and Allowances [Rule-13]
Clearly Allocable to an Income Not clearly Allocable to an Income
deductible/chargeable
against that particular income
Apportion on basis of following formula:
Common Exp x Gross Receipts of a class of income/Gross Receipts of all classes of income
Class of Income may include following:
Salary Income
Income from Property
Income from Business (Speculative/Non Speculative)
Capital Gains
Other Sources
Separate Block of Income
Exempt Income
Income under FTR
Pakistan
Source
Income
Foreign
Source
Income
25
6. Apportionment of Deductions [Rule 13]
a) Gross receipts are net of Sales Tax & Federal Excise Duty
b) Nature and source of each class of income shall be considered for allocation
c) Above allocation shall be certified by CA or CMA
d) In case accounts are not required to be audited then certificate shall be obtained for basis of allocation. The said
certificate is required to be accepted by CIR who shall accept it only if variation in allocation from these rules is
not more than 10%
e) In certain transactions where net gains, brokerage, commission or other income is taken, than Gross Profits shall
be taken as Gross Receipts
26
a) Total Income [S-10]
b) Taxable Income [S-9]
c) Heads of Income [S-11]
d) Tax on Taxable Income [S-4]
27
Final Tax Regime
Advance Tax Tax at Source
Section 169
[S-148] Imports
[S-148A] Local Purchase of Cooking Oil & Vegetable Ghee
[S-234A] CNG Stations
[S-151] Profit on debt
[S-152] Payments to Non Residents
[S-153] Payment of Goods, Services or Contracts
[S-154] Exports
[S-156] Prizes & Winnings
[S-156A] Petroleum Products
[S-233] Brokerage & Commission
[S-152A] Payment for Foreign Produced Commercials
[S-236A] Advance Tax at the time of sale by Auction
[S-236M] Bonus Shares issued by Companies Quoted on Stock
Exchange
[S-236N] Bonus Shares issued by Companies not Quoted on Stock
Exchange
[S-236Q] Payment to Residents for use of Machinery & Equipment
[S-236S] Dividend in Specie
Others
28
[S-148] Imports
Final Tax Regime
• Collector of Customs shall collect ADVANCE TAX on imports @ 1st Schedule, Part-II at the time and in the manner, custom duty is paid
• Above tax on Imports shall be :
Adjustable Tax in following cases:
i. Import of Raw Material, Plant & Machinery, Equipment &
Parts by Industrial Undertaking for its own use
ii. Import of Fertilizer by Manufacturer of Fertilizer
iii. Import of Motor Vehicle in CBU condition by Manufacturer of
Motor Vehicles
iv. Imports by Large Import House
v. Import of Foreign Produced Film for viewing and screening
Minimum Tax in following cases:
i. Import of Edible Oil [including crude oil
imported as raw material of manufacture of
ghee or cooking oil]
ii. Import of Packing Material
Final Tax in following cases:
i. Import of ship by ship breaker
ii. Any other imports not mentioned
earlier
• have paid-up capital of exceeding Rs.250 million;
• have imports exceeding Rs.500 million;
• own total assets exceeding Rs.350 million at the
close of the TY;
• is single object company;
• maintain computerized records of imports and sale
of goods;
• maintain a system for issuance of 100% cash
receipts on sales;
• present accounts for tax audit every year;
• is registered under the Sales Tax Act, 1990 and
• make sales of industrial raw material of
manufacturer registered under the Sales Tax
Act,1990
29
[S-148A] Local Purchase of Cooking Oil or Vegetable Ghee
Final Tax Regime
• Purchase of locally produced edible oil by Manufacturer of Cooking Oil or Vegetable Ghee shall be charged to tax at following rate:
2% of Purchase of locally produced edible oil
• Above tax shall be final tax in respect of income accruing from locally produced edible oil
30
[S-234A] CNG Station
Final Tax Regime
Person preparing Gas consumption bill
Charge tax @ 1st Sched, Part-III, Div-VIB
CNG StationBill
31
[S-151] Profit on Debt
Final Tax Regime
Payer of POD
Deduct tax @
1st Sched, Part-III, Div-IA
Gross POD X
- Zakat (X)
X
• Account
• Deposit
• Certificate
• Post Office Savings Account
• Account
• Deposit
• Security issued by FG/PG/LG
• Bond
• Debenture
• Certificate
• Security
• Instrument of any kind
of National Saving Scheme
with any Bank/Financial Institution
Issued by:
Banking Co
Financial Institution
Company as defined in Co. Ord. 1984
Body Corporate formed under any Law
To any Resident Person
To any Resident Person
other than Financial
Institution
Tax deduction shall not be made from Profit on Debt on
Loan Agreement between borrower and Banking
Company OR Financial Institution
Tax deducted under Section 151, shall be ADJUSTABLE
against tax liability calculated under Section 7B, which
will be calculated @ 1st Sched, Part-I, Div-IIIA on Gross
Amount of Profit on Debt
Tax Liability under Section 7B, shall be Final Tax
Section 7B is not applicable on Company, therefore Profit
on Debt received by Company shall be taxed under
Normal Tax Regime and tax deducted under section 151
shall be adjustable
32
Not Applicable
FTR
Company
Tax Imposed Final Tax
NTR
Other CasesSection 7BCompany
Tax deducted at source
Section 151
Other Cases
Not Final Tax
Final Tax
Separate Taxation
33
[S-152] Payments to Non Residents
Final Tax Regime
Every person while making payment to Non Resident for
Contract of
[S-152(1A)]
Advertising Services
by Non Resident Media
Person relaying from
outside Pakistan
[S-152(1AAA)]
Insurance/
Reinsurance
Premium
[S-152(1AA)]
Advertisement
Services
rendered by TV
Satellite Channel
Construction
Assembly
Installation in
Pakistan
Supervisory
activity in
relation to
above
premium should
not be taxable
income of PE of
Non Resident
Deduct tax @ 1st Sched, Part-III, Div-II
Final Tax
34
[S-153] Payments for Goods, Services, Contracts
Final Tax Regime
Every Prescribed Person while making payment to Resident shall deduct tax @ 1st Sched, Part-III, Div-III for payment on account of following
Final Tax
Goods
[S-153(1)(a)]
Other CasesListed CompanyCompany
(being manufacturer)
OthersSports PersonListed Company
Other than for sale of goods or services
Contracts
[S-153(1)(c)]
Services
[S-153(1)(b)]
Minimum Tax
Adjustable Tax
Section 153(2): Exporter/Export House making payment to Resident
Person OR PE of Non Resident for services of stitching, dying, printing,
embroidery, washing, sizing and weaving shall
deduct tax @ 1st Sched, Part-III, Div-IV ResidentPENR
35
[S-154] ExportsFinal Tax Regime
Indirect ExporterIndirect ExporterExporter
Indenting Commission
Agent
Direct ExporterDirect ExporterFrom
Direct ExporterBankExport Processing
Zone Authority
Authorized Dealer in
Forex
Collector of Customs
Authorized Dealer in
Forex
By
Payment of GoodsRealization of Proceeds
Time of Export
Realization of Forex
Proceeds
Time of Export
Realization of Forex
ProceedsTime
[S-154(3B)][S-154(3)][S-154(3A)] [S-154(2)][S-154(3C)][S-154(1)]
Tax Collection
Rate 1st Sched, Part-III, Div-IV
Tax deducted/collected above shall be Final Tax, however, a person may opt not to be subject to final taxation. In case of availing such option, the above taxes shall be
treated as minimum tax
In Land Back-to-
back letter of credit
Firm contract Forex Pak Rupees (i.e.,
exports without
Form "E")
Sales made to Direct exporter through Export Proceeds Realizable in
Indirect Exporter Direct Exporter
Yes No
Export of Goods by Industrial Undertaking in Export Processing Zone Commission on
Exports
36
[S-156] Prizes & WinningsFinal Tax Regime
Every person paying following shall deduct/collect tax @ 1st Sched, Part-III, Div-VI
• Prize Bond
• Winning from raffle
• Lottery
• Prize on a quize
• Sale promotion prize by a company
• Cross word puzzle
Tax shall be deducted from gross amount, in case of cash prize OR
on fair market value, in case of prize in kind
Tax collected/deducted shall be Final Tax
37
[S-156A] Petroleum ProductsFinal Tax Regime
Every person selling petroleum products to petrol pump operator shall deduct tax on
discount or commission allowed to petrol pump operator
at the rate mentioned in 1st Sched, Part-III, Div-VIA
Tax deducted shall be Final Tax
38
[S-233] Brokerage & CommissionFinal Tax Regime
Principal Agent
Brokerage /
Commission
Faderal Govt,
Provincial Govt,
Local Govt,
Company,
AOP formed under any Law
Deduct tax @
1st Sched, Part-IV, Div-II
Tax deducted shall be Final Tax
If agent has retained any commission or brokerage from amount remitted to principal, such amount shall be deemed to have been
paid by principal to the agent and tax thereon shall be collected by principal from agent.
39
[S-152A] Payment for Foreign Produced CommercialsFinal Tax Regime
Any Person Non Resident Person
Tax deducted shall be Final Tax
Foreign produced commercial for advertisement
On
Television or other media
Direct Payment
Through agent
or intermediary
Deduct tax
@ 20%
From Gross amount
40
[S-236A] Advance tax at time of sale by auctionFinal Tax Regime
SellerPurchaserPublic Auction Auction by Tender
Property attached/confiscated
OR
Awarding of any lease to any person
Including:
lease of the right to collect tolls
fees or other levies
Belonging/Not belonging to:
Government
Local Government
Any authority
Company
Foreign association declared to be a company [S-80(2)(b)(vi)]
Foreign contractor/consultant/consortium
Collector of Customs
Commissioner of Inland Revenue
Any any other authority
Collect tax
@
1st Sched, Part-IV, Div-VIII
On sale price
Final Tax
41
[S-236M] Bonus Shares issued by Listed CompaniesFinal Tax Regime
ShareholderListed Company Bonus Shares
Withhold
5%
Bonus Shares
Remaining Shares
Pay tax
@ 5%
Share Price
Day-end price on
1st day of book
closure
Collect tax with in 15
days of book closure
Tax not paid by
shareholder
Deposit shares with
CDC/prescribed entity
Deposit shares with
CDC/prescribed entity
Dispose off shares
(pay to CIT - FBR)
Final Tax
Release Shares
42
[S-236N] Bonus Shares issued by Un-quoted CompaniesFinal Tax Regime
ShareholderUn-listed Company Bonus Shares
Co. shall pay tax @ 5%
Bonus Shares & collect
it from Sh.holder
Remaining Shares
Pay tax
@ 5%
Share Price
Day-end price on
1st day of book
closure
To be paid to FBR with in
15 days of book closure
Tax not paid by shareholder
OR
Shares not collected by shareholder
Company shall
dispose off shares
(pay to CIT - FBR)
Final Tax
Release Shares
43
[S-236Q] Payment to Resident for use of Machinery & EquipmentFinal Tax Regime
Prescribed Person
Making payment to Resident Person
For use/right to use
Industrial/commercial/scientific equipment
On account of RENT of machinery
Deduct tax on Gross Amount
1st Sched, Part-IV, Div-XXIII
Final Tax
Prescribed Person has same meaning
as defined in Section 153(7)
Machinery leased by:
- Leasing Co.
- Investment bank
- Modaraba
- Scheduled bank
- Development finance Inst.
Agriculture Machinery
This section not applicable on following:
44
Separate Block
Separate Taxation Separate Block
Section 8 [S-5] Tax on Dividends
[S-5A] Tax on Undistributed Reserves
[S-5AA] Tax on Investment in Sukuks
[S-6] Tax on certain payments to Non Residents
[S-7] Tax on shipping and air transport income of a
non-resident person
[S-7A] Tax on shipping of Resident Person
[S-7B] Tax on Profit on Debt
[S-7C] Tax on Builders
[S-7D] Tax on Developers
• To be discussed in
relevant Head of Income
45
Dividend
Separate Block
Company Shareholder
Deduct tax on gross amount @ 1st Sched, Part-III, Div-I
Cash Dividend
[S-150]
Dividend in specie
[S-236S]
Tax deducted will be Adjustable
Pay tax on gross amount @ 1st Sched, Part-I, Div-III
Tax Imposed will be Final Tax
[S-5]
Shareholder shall pay Final Tax after adjustment of tax
deducted at source
46
[S-5A] Undistributed Reserves of Public Company
Separate Block
Public Company
(Other than Scheduled Bank or Modaraba)
50% or more shares held by FG Electric Power Generation
Company exempt under 2nd
Schedule, Part-I, Clause 132
Cash Dividend is paid upto
Cash Dividend is paid lower
than the limit
No Cash dividend paid
40% of Profit after tax
OR
50% of paid up capital
which ever is less
Undistributed Reserves X
- Paid up capital (X)
X
Treated as Deemed Income
Taxable @ 10%
Final Tax on Deemed Income
This section not applicable Includes:
• Revenue Reserves
• Reserves Created out of profits
Does not include:
• Capital Reserves
• Share Premium
• Reserves required to be created under any law
Cash dividend must be distributed within
6 months from end of tax year
47
Return on Sukuk
Separate Block
Special Purpose Vehicle Sukuk Holder
Deduct tax on gross amount @ 1st Sched, Part-III, Div-IB
Return on Sukuk
[S-150A]
Tax deducted will be Adjustable
Pay tax on gross amount @ 1st Sched, Part-I, Div-IIIB
Tax Imposed will be Final Tax
[S-5AA]
Receiver of return shall pay Final Tax after adjustment
of tax deducted at source
3rd Pak Int Sukuk Co
48
Special Purpose Vehicle
Wapda
Wapda
First
Sukuk
Company
Ltd
Sukuk
Holder
Sukuk Certificate
Funds for Purchase of Turbines Funds
Title to Turbines
Lease Turbines
Lease Rental Return to Sukuk Holder
Pay Exercise Price
Get Title of Turbines
Redeem Sukuk
Return Sukuk
Purchase
Turbines
49
Payments to Non ResidentsSeparate Block
Payment to Non Resident
for Pakistan Source
Royalty OR FFTS Non-Resident
Deduct tax on gross amount @ 1st Sched, Part-I, Div-IV
Payment to Non Resident
[S-152(1)]
Tax deducted will be Adjustable
Pay tax on gross amount @ 1st Sched, Part-I, Div-IV
Tax Imposed will be Final Tax
[S-6]
This section shall not apply on following:
1. Royalty: where property or right giving rise to royalty is effectively
connected with PE of Non Resident. Such royalty shall be treated as
business income of PE of Non Resident.
2. FFTS: where services giving rise to fee are rendered through PE of Non
Resident. Such fee shall be treated as business income of PE of Non
Resident.
3. Royalty or FFTS exempt from tax.
50
[S-2(54)] Royalty
Royalty means any amount Paid Payable Periodical or lumpsum as consideration for following
(vi)
(vii)
supply of any assistance ancillary and subsidiary to any property or right mentioned above
disposal of any right or property mentioned above
(v) Use or right to use Industrial/commercial/scientific equipment
(iv) Supply of Technical/industrial/commercial/scientific Knowledge/skill
(iii)
receive or right to receive
visual image or sound
transmitted by
Satellite/Cable
Optic Fiber
Similar technology
in connection with
Television
Radio
Internet broadcasting
(ii) Use or right to use
copyright or a literary, artistic or scientific work including
films or video tapes for use in connection with television or
tapes in connection with radio broadcasting
but shall not include consideration for
sale, distribution or exhibition of
cinematograph films
(i) Use or right to use Patent
Invention
Design
Model
Secret formula
Process
Trade mark
Other like property/right
51
[S-2(23)] FFTS
means any consideration, whether periodical or lump sum, for rendering :
(b) consideration chargeable under head "Salary"
(a) consideration for services in connection with construction, assembly or like project
It does not include following
Including services of technical or other personnel
Managerial
Technical
Consultancy Services
52
[S-7] Tax on Shipping & Air Transport Business of Non-ResidentSeparate Block
Non-Resident owns a ship or aircraft
Tax shall be imposed @ 1st Sched, Part-I, Div-V
Tax Imposed will be Final Tax
On Gross Amount
Passengers, live stock, mail, goods
embarked
In Pakistan Outside Pakistan
Amount
Received/Receivable
In Pakistan P P
Outside Pakistan P O
53
[S-7A] Tax on Shipping of Resident PersonSeparate Block
Resident doing shipping business
Ships flying Pakistan Flag
@ 1 US $ per Gross Registered Tonnage
Pay Tonnage Tax
Ships not registered in Pakistan
Pay Tonnage Tax
0.15 US $ per Gross Registered Tonnage
For each voyage to Pakistan
Subject to maximum of 1 US $ per
Gross Registered Tonnage
Exchange rate on following dates shall be applicable:
i. In case of Company, 1st December of relevant Tax Year
ii. In other cases, 1st September of relevant Tax Year
Tax paid under this section shall be Final Tax
This section shall not be applicable after 30.06.2020
54
[S-7C] Tax on BuildersSeparate Block
Person deriving income from business of
Construction & Sale of
residential/commercial/other building
@ 1st Sched, Part-I, Div-VIIIA
Pay tax on basis of area of building constructed
On business or projects initiated/approved after 01.7.2016
FHR may prescribe following:
i. mode/manner for payment/collection of tax
ii. Authority who will grant approval for computation and payment plan of tax
iii. Responsibilities/powers of authorities who will approve/suspend/cancel NOC to sell the property
55
[S-7D] Tax on DevelopersSeparate Block
Person deriving income from business of
Development & Sale of
residential/commercial/other Plots
@ 1st Sched, Part-I, Div-VIIIB
Pay tax on basis of area of Plot
On business or projects initiated/approved after 01.7.2016
FHR may prescribe following:
i. mode/manner for payment/collection of tax
ii. Authority who will grant approval for computation and payment plan of tax
iii. Responsibilities/powers of authorities who will approve/suspend/cancel NOC to sell the property

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Advanced Taxation (CFAP5) by Fawad Hassan [Lecture1]

  • 1. CFAP – 05 Advanced Taxation [Trainer: Fawad Hassan – ACA]
  • 2. 2 Dos and Don’ts 1. Referring too many books 2. Optimize Memory Utilization 3. Improvise Retrieval Ability 4. First understand “The Big Picture” – Taxation Framework/Mechanism 5. Then “Zoom In” for details
  • 3. 3 Expectations 1. Understanding of Taxation Laws 2. Application of Understanding
  • 4. 4 Syllabus Grid Weighting Last 8 years’ Average Income Tax 50-55 59 Sales Tax 30-35 28 Faderal Excise Law 10-15 12 Professional values, ethics and attitude 5-10 1 Details
  • 5. 5 Revenue Collection Exchequer (FederalConsolidatedFund) Inflows Outflows Income Tax CVT WWF Sales Tax FED Custom Duty DeficitLoans & Grants Capital Receipts Revenue Receipts Non Tax Receipts Tax Receipts Other Taxes FBR Taxes Indirect Tax Direct Tax External Receipts Internal Receipts
  • 6. 6 Income Tax 6 Basic Questions 1. Tax Year 2. Type of Person 3. Residential Status 4. Tax Regime 5. Geographical Source of Income 6. Apportionment of Deductions
  • 7. 7 1. Tax Year [S-74] Time Bracket Normal Tax Year (NTY) End date is other than 30th June End date is 30th June Time period of less than 12 months Time period of 12 months Transitional Tax Year (TTY) Special Tax Year (STY) Denoted by Calendar Year relevant to NTY in which Year end falls Denoted by Calendar Year in which NTY ends Denoted by Calendar Year relevant to NTY in which Year end falls FBR has authority to prescribe STY TTY occurs because of change in TY from NTY to STY or vice versa TTY is the period between TY end date of last tax year and commencement date of next TY Industry Special Tax Year SRO Ref Sugar Manufacturing 1st October - 30th September 134(R)/68, July 31,1968 Rice Exporter 1st January - 31st December 367(I) /74, January 14,1974 Insurance 1st January - 31st December 878 (I) /95, August 30,1995
  • 8. 8 Change in Tax Year NTY STY STY - 1 STY - 2STY NTY Tax Payer will give an application in writing to Commissioner of Income Tax (CIT) CIT is convinced that compelling need exists Not Convinced Give tax payer an opportunity of being heard in person Not Convinced 1) issue rejection orders 2) record reasons of rejection in order Tax Payer may file review application to FBR & decision of FBR shall be final Grant Permission through an order in writing
  • 9. 9 Tax Year Practice Determine the tax year in respect of each accounting periods mentioned below: a) 1.09.2015 to 31.08.2016 b) 01.04.2016 to 30.06.2016 c) 1.01.2016 to 31.12.2016 d) 1.04.2016 to 31.03.2017 e) 1.05.2016 to 30.04.2017 f) 1.07.2016 to 30.06.2017 STY TTY STY STY STY NTY TY 2017 TY 2016 TY 2017 TY 2017 TY 2017 TY 2017
  • 10. 10 2. Type of Person a) Tax Payer [S-2(66)] b) Person [S-80]
  • 11. 11 a) Tax Payer [S-2(66)] Any person or representative of person who; i. Derives an amount chargeable to tax ii. Is required to collect/deduct tax iii. is required to furnish return of income iv. is required to pay tax under Income Tax Ordinance 2001
  • 12. 12 b) Person [S-80] Following shall be treated as person; i. Individual ii. Company formed in Pakistan or elsewhere iii. AOP formed in Pakistan or elsewhere iv. Federal government v. Foreign government vi. Political subdivision of foreign government vii. Public International Organization
  • 13. 13 Company means following i. Company as defined in Companies Ordinance 1984 ii. Body Corporate formed by or under any law in force in Pakistan iii. Modaraba iv. body incorporated by or under any law of country outside Pakistan relating to incorporation of companies v. cooperative society, finance society or any other society vi. non-profit organization vii. Trust viii. foreign association declared by FBR to be a company ix. Provincial Government x. Local Government xi. Small company as defined in Section -2
  • 14. 14 Association of Persons includes following i. Firm (means relation between persons who have agreed to share profits of business carried on by all or any one of them acting for all) ii. Hindu Undivided Family iii. Artificial Juridical Person iv. Any body of persons formed under foreign law And does not include “Company”
  • 15. 15 3. Residential Status a) Resident Individual b) Resident Company c) Resident AOP
  • 16. 16 a) Resident Individual [S-82] i. Not based on Nationality ii. Based on Physical Presence in Pakistan iii. Government servant posted abroad will be treated as resident, irrespective of his physical stay in Pakistan iv. Counting of days shall be made in accordance with Rule-14 of Income Tax Rules, 2002 0 – 182 days 183 days or more Non Resident Resident
  • 17. 17 Rule-14 of Income Tax Rules, 2002 Days not to be counted Days to be counted i. Day or part of day in Pakistan solely by reason of being in transit between two different places outside Pakistan Part of a day shall be counted as a whole day in following cases; i. Day of arrival in Pakistan ii. Day of departure from Pakistan iii. Public Holiday iv. Leave, including sick leave v. Holiday spent in Pakistan before, during or after activity in Pakistan vi. Day when activity was interrupted due to Strike, lockout, delay in receipt of supplies
  • 18. 18 b) Resident Company [S-83] i. Company incorporated in Pakistan ii. Provincial Government iii. Local Government iv. Company incorporated outside Pakistan Resident No further condition required Resident if, Control and Management of affairs situated wholly in Pakistan at any time in a Tax Year
  • 19. 19 b) Resident AOP [S-84] Resident if, Control and Management of affairs situated wholly or partly in Pakistan at any time in a Tax Year
  • 20. 20 Residential Status Practice i. Mr. Raza is working as Director Operations in the Ministry of Tourism. On 15 July 2016 he was posted to Pakistan Embassy in Italy for two years. ii. Anderson LLC was incorporated as limited liability Company in UK. The control and management of its affairs was situated wholly in Pakistan. However, with effect from 01 November 2016, the entire management and control was shifted to UK. iii. On 01 February 2017, Mr. Sameel was sent to Pakistan by his UK based company to work on a special project. He left Pakistan on 23 August 2017. iv. BBL is a non-listed public company incorporated under the Companies Ordinance, 1984. All the shareholders of the company are individuals. The control and management of affairs of the company during the year was outside Pakistan. v. Mr. Salman a property dealer in USA came to Pakistan on 01 February 2016. During his stay upto 02 August 2016 in Pakistan, he remained in Peshawar upto 30 June 2016 and thereafter till his departure from Pakistan, in Quetta. Assume that Commissioner has granted him permission to use calendar year as special tax year. vi. Peshawar LLC (PLLC) was incorporated as a limited liability company in UAE. PLLC has 5 directors out of which 2 are involved in management, the rest of them were situated in UAE. The 2 directors control the affairs of the company from Pakistan. Resident Resident Non Resident Resident Resident Resident Federal Govt Employee Control & Mngt in wholly in Pak any time in TY Stay less than 180 days Company incorporated in Pak Total stay 184 days Control & Mngt in wholly in Pak any time in TY
  • 21. 21 4. Tax Regimes Heads of Income Salary Income Property Income Business Income Capital Gains Income from Other Sources Total Income - Deductible Allowances Taxable Income Rate from 1st Schedule Tax Imposed/Chargeable - Tax Credits Tax Payable - Withholding Tax/Adv Tax Income Tax Demand/Refund Normal Tax Reg. Separate Block Final Tax Reg Minimum Tax Reg 10 10 10 10 10 10% 50 (2) (10) 1 40 4 (1) 3
  • 22. 22 5. Geographical Source of Income a) Pakistan Source Income [S-2(40) & 101] b) Foreign Source Income [S-2(27) & 101(16)] Resident Non Resident Pakistan Source Income Taxable Taxable Foreign Source Income Taxable Not Taxable
  • 23. 23 6. Apportionment of Deductions [S-67 & Rule 13] Apportionment of Deductions [S-67] Any expenditure/deduction/allowance that relates with following shall be apportioned on reasonable basis: a) derivation of income under more than one head of income b) derivation of taxable income and income under Final Tax Regime c) derivation of income under any head of income and for any other purpose
  • 24. 24 6. Apportionment of Deductions [S-67 & Rule 13] Apportionment of Expenditures Deductions and Allowances [Rule-13] Clearly Allocable to an Income Not clearly Allocable to an Income deductible/chargeable against that particular income Apportion on basis of following formula: Common Exp x Gross Receipts of a class of income/Gross Receipts of all classes of income Class of Income may include following: Salary Income Income from Property Income from Business (Speculative/Non Speculative) Capital Gains Other Sources Separate Block of Income Exempt Income Income under FTR Pakistan Source Income Foreign Source Income
  • 25. 25 6. Apportionment of Deductions [Rule 13] a) Gross receipts are net of Sales Tax & Federal Excise Duty b) Nature and source of each class of income shall be considered for allocation c) Above allocation shall be certified by CA or CMA d) In case accounts are not required to be audited then certificate shall be obtained for basis of allocation. The said certificate is required to be accepted by CIR who shall accept it only if variation in allocation from these rules is not more than 10% e) In certain transactions where net gains, brokerage, commission or other income is taken, than Gross Profits shall be taken as Gross Receipts
  • 26. 26 a) Total Income [S-10] b) Taxable Income [S-9] c) Heads of Income [S-11] d) Tax on Taxable Income [S-4]
  • 27. 27 Final Tax Regime Advance Tax Tax at Source Section 169 [S-148] Imports [S-148A] Local Purchase of Cooking Oil & Vegetable Ghee [S-234A] CNG Stations [S-151] Profit on debt [S-152] Payments to Non Residents [S-153] Payment of Goods, Services or Contracts [S-154] Exports [S-156] Prizes & Winnings [S-156A] Petroleum Products [S-233] Brokerage & Commission [S-152A] Payment for Foreign Produced Commercials [S-236A] Advance Tax at the time of sale by Auction [S-236M] Bonus Shares issued by Companies Quoted on Stock Exchange [S-236N] Bonus Shares issued by Companies not Quoted on Stock Exchange [S-236Q] Payment to Residents for use of Machinery & Equipment [S-236S] Dividend in Specie Others
  • 28. 28 [S-148] Imports Final Tax Regime • Collector of Customs shall collect ADVANCE TAX on imports @ 1st Schedule, Part-II at the time and in the manner, custom duty is paid • Above tax on Imports shall be : Adjustable Tax in following cases: i. Import of Raw Material, Plant & Machinery, Equipment & Parts by Industrial Undertaking for its own use ii. Import of Fertilizer by Manufacturer of Fertilizer iii. Import of Motor Vehicle in CBU condition by Manufacturer of Motor Vehicles iv. Imports by Large Import House v. Import of Foreign Produced Film for viewing and screening Minimum Tax in following cases: i. Import of Edible Oil [including crude oil imported as raw material of manufacture of ghee or cooking oil] ii. Import of Packing Material Final Tax in following cases: i. Import of ship by ship breaker ii. Any other imports not mentioned earlier • have paid-up capital of exceeding Rs.250 million; • have imports exceeding Rs.500 million; • own total assets exceeding Rs.350 million at the close of the TY; • is single object company; • maintain computerized records of imports and sale of goods; • maintain a system for issuance of 100% cash receipts on sales; • present accounts for tax audit every year; • is registered under the Sales Tax Act, 1990 and • make sales of industrial raw material of manufacturer registered under the Sales Tax Act,1990
  • 29. 29 [S-148A] Local Purchase of Cooking Oil or Vegetable Ghee Final Tax Regime • Purchase of locally produced edible oil by Manufacturer of Cooking Oil or Vegetable Ghee shall be charged to tax at following rate: 2% of Purchase of locally produced edible oil • Above tax shall be final tax in respect of income accruing from locally produced edible oil
  • 30. 30 [S-234A] CNG Station Final Tax Regime Person preparing Gas consumption bill Charge tax @ 1st Sched, Part-III, Div-VIB CNG StationBill
  • 31. 31 [S-151] Profit on Debt Final Tax Regime Payer of POD Deduct tax @ 1st Sched, Part-III, Div-IA Gross POD X - Zakat (X) X • Account • Deposit • Certificate • Post Office Savings Account • Account • Deposit • Security issued by FG/PG/LG • Bond • Debenture • Certificate • Security • Instrument of any kind of National Saving Scheme with any Bank/Financial Institution Issued by: Banking Co Financial Institution Company as defined in Co. Ord. 1984 Body Corporate formed under any Law To any Resident Person To any Resident Person other than Financial Institution Tax deduction shall not be made from Profit on Debt on Loan Agreement between borrower and Banking Company OR Financial Institution Tax deducted under Section 151, shall be ADJUSTABLE against tax liability calculated under Section 7B, which will be calculated @ 1st Sched, Part-I, Div-IIIA on Gross Amount of Profit on Debt Tax Liability under Section 7B, shall be Final Tax Section 7B is not applicable on Company, therefore Profit on Debt received by Company shall be taxed under Normal Tax Regime and tax deducted under section 151 shall be adjustable
  • 32. 32 Not Applicable FTR Company Tax Imposed Final Tax NTR Other CasesSection 7BCompany Tax deducted at source Section 151 Other Cases Not Final Tax Final Tax Separate Taxation
  • 33. 33 [S-152] Payments to Non Residents Final Tax Regime Every person while making payment to Non Resident for Contract of [S-152(1A)] Advertising Services by Non Resident Media Person relaying from outside Pakistan [S-152(1AAA)] Insurance/ Reinsurance Premium [S-152(1AA)] Advertisement Services rendered by TV Satellite Channel Construction Assembly Installation in Pakistan Supervisory activity in relation to above premium should not be taxable income of PE of Non Resident Deduct tax @ 1st Sched, Part-III, Div-II Final Tax
  • 34. 34 [S-153] Payments for Goods, Services, Contracts Final Tax Regime Every Prescribed Person while making payment to Resident shall deduct tax @ 1st Sched, Part-III, Div-III for payment on account of following Final Tax Goods [S-153(1)(a)] Other CasesListed CompanyCompany (being manufacturer) OthersSports PersonListed Company Other than for sale of goods or services Contracts [S-153(1)(c)] Services [S-153(1)(b)] Minimum Tax Adjustable Tax Section 153(2): Exporter/Export House making payment to Resident Person OR PE of Non Resident for services of stitching, dying, printing, embroidery, washing, sizing and weaving shall deduct tax @ 1st Sched, Part-III, Div-IV ResidentPENR
  • 35. 35 [S-154] ExportsFinal Tax Regime Indirect ExporterIndirect ExporterExporter Indenting Commission Agent Direct ExporterDirect ExporterFrom Direct ExporterBankExport Processing Zone Authority Authorized Dealer in Forex Collector of Customs Authorized Dealer in Forex By Payment of GoodsRealization of Proceeds Time of Export Realization of Forex Proceeds Time of Export Realization of Forex ProceedsTime [S-154(3B)][S-154(3)][S-154(3A)] [S-154(2)][S-154(3C)][S-154(1)] Tax Collection Rate 1st Sched, Part-III, Div-IV Tax deducted/collected above shall be Final Tax, however, a person may opt not to be subject to final taxation. In case of availing such option, the above taxes shall be treated as minimum tax In Land Back-to- back letter of credit Firm contract Forex Pak Rupees (i.e., exports without Form "E") Sales made to Direct exporter through Export Proceeds Realizable in Indirect Exporter Direct Exporter Yes No Export of Goods by Industrial Undertaking in Export Processing Zone Commission on Exports
  • 36. 36 [S-156] Prizes & WinningsFinal Tax Regime Every person paying following shall deduct/collect tax @ 1st Sched, Part-III, Div-VI • Prize Bond • Winning from raffle • Lottery • Prize on a quize • Sale promotion prize by a company • Cross word puzzle Tax shall be deducted from gross amount, in case of cash prize OR on fair market value, in case of prize in kind Tax collected/deducted shall be Final Tax
  • 37. 37 [S-156A] Petroleum ProductsFinal Tax Regime Every person selling petroleum products to petrol pump operator shall deduct tax on discount or commission allowed to petrol pump operator at the rate mentioned in 1st Sched, Part-III, Div-VIA Tax deducted shall be Final Tax
  • 38. 38 [S-233] Brokerage & CommissionFinal Tax Regime Principal Agent Brokerage / Commission Faderal Govt, Provincial Govt, Local Govt, Company, AOP formed under any Law Deduct tax @ 1st Sched, Part-IV, Div-II Tax deducted shall be Final Tax If agent has retained any commission or brokerage from amount remitted to principal, such amount shall be deemed to have been paid by principal to the agent and tax thereon shall be collected by principal from agent.
  • 39. 39 [S-152A] Payment for Foreign Produced CommercialsFinal Tax Regime Any Person Non Resident Person Tax deducted shall be Final Tax Foreign produced commercial for advertisement On Television or other media Direct Payment Through agent or intermediary Deduct tax @ 20% From Gross amount
  • 40. 40 [S-236A] Advance tax at time of sale by auctionFinal Tax Regime SellerPurchaserPublic Auction Auction by Tender Property attached/confiscated OR Awarding of any lease to any person Including: lease of the right to collect tolls fees or other levies Belonging/Not belonging to: Government Local Government Any authority Company Foreign association declared to be a company [S-80(2)(b)(vi)] Foreign contractor/consultant/consortium Collector of Customs Commissioner of Inland Revenue Any any other authority Collect tax @ 1st Sched, Part-IV, Div-VIII On sale price Final Tax
  • 41. 41 [S-236M] Bonus Shares issued by Listed CompaniesFinal Tax Regime ShareholderListed Company Bonus Shares Withhold 5% Bonus Shares Remaining Shares Pay tax @ 5% Share Price Day-end price on 1st day of book closure Collect tax with in 15 days of book closure Tax not paid by shareholder Deposit shares with CDC/prescribed entity Deposit shares with CDC/prescribed entity Dispose off shares (pay to CIT - FBR) Final Tax Release Shares
  • 42. 42 [S-236N] Bonus Shares issued by Un-quoted CompaniesFinal Tax Regime ShareholderUn-listed Company Bonus Shares Co. shall pay tax @ 5% Bonus Shares & collect it from Sh.holder Remaining Shares Pay tax @ 5% Share Price Day-end price on 1st day of book closure To be paid to FBR with in 15 days of book closure Tax not paid by shareholder OR Shares not collected by shareholder Company shall dispose off shares (pay to CIT - FBR) Final Tax Release Shares
  • 43. 43 [S-236Q] Payment to Resident for use of Machinery & EquipmentFinal Tax Regime Prescribed Person Making payment to Resident Person For use/right to use Industrial/commercial/scientific equipment On account of RENT of machinery Deduct tax on Gross Amount 1st Sched, Part-IV, Div-XXIII Final Tax Prescribed Person has same meaning as defined in Section 153(7) Machinery leased by: - Leasing Co. - Investment bank - Modaraba - Scheduled bank - Development finance Inst. Agriculture Machinery This section not applicable on following:
  • 44. 44 Separate Block Separate Taxation Separate Block Section 8 [S-5] Tax on Dividends [S-5A] Tax on Undistributed Reserves [S-5AA] Tax on Investment in Sukuks [S-6] Tax on certain payments to Non Residents [S-7] Tax on shipping and air transport income of a non-resident person [S-7A] Tax on shipping of Resident Person [S-7B] Tax on Profit on Debt [S-7C] Tax on Builders [S-7D] Tax on Developers • To be discussed in relevant Head of Income
  • 45. 45 Dividend Separate Block Company Shareholder Deduct tax on gross amount @ 1st Sched, Part-III, Div-I Cash Dividend [S-150] Dividend in specie [S-236S] Tax deducted will be Adjustable Pay tax on gross amount @ 1st Sched, Part-I, Div-III Tax Imposed will be Final Tax [S-5] Shareholder shall pay Final Tax after adjustment of tax deducted at source
  • 46. 46 [S-5A] Undistributed Reserves of Public Company Separate Block Public Company (Other than Scheduled Bank or Modaraba) 50% or more shares held by FG Electric Power Generation Company exempt under 2nd Schedule, Part-I, Clause 132 Cash Dividend is paid upto Cash Dividend is paid lower than the limit No Cash dividend paid 40% of Profit after tax OR 50% of paid up capital which ever is less Undistributed Reserves X - Paid up capital (X) X Treated as Deemed Income Taxable @ 10% Final Tax on Deemed Income This section not applicable Includes: • Revenue Reserves • Reserves Created out of profits Does not include: • Capital Reserves • Share Premium • Reserves required to be created under any law Cash dividend must be distributed within 6 months from end of tax year
  • 47. 47 Return on Sukuk Separate Block Special Purpose Vehicle Sukuk Holder Deduct tax on gross amount @ 1st Sched, Part-III, Div-IB Return on Sukuk [S-150A] Tax deducted will be Adjustable Pay tax on gross amount @ 1st Sched, Part-I, Div-IIIB Tax Imposed will be Final Tax [S-5AA] Receiver of return shall pay Final Tax after adjustment of tax deducted at source 3rd Pak Int Sukuk Co
  • 48. 48 Special Purpose Vehicle Wapda Wapda First Sukuk Company Ltd Sukuk Holder Sukuk Certificate Funds for Purchase of Turbines Funds Title to Turbines Lease Turbines Lease Rental Return to Sukuk Holder Pay Exercise Price Get Title of Turbines Redeem Sukuk Return Sukuk Purchase Turbines
  • 49. 49 Payments to Non ResidentsSeparate Block Payment to Non Resident for Pakistan Source Royalty OR FFTS Non-Resident Deduct tax on gross amount @ 1st Sched, Part-I, Div-IV Payment to Non Resident [S-152(1)] Tax deducted will be Adjustable Pay tax on gross amount @ 1st Sched, Part-I, Div-IV Tax Imposed will be Final Tax [S-6] This section shall not apply on following: 1. Royalty: where property or right giving rise to royalty is effectively connected with PE of Non Resident. Such royalty shall be treated as business income of PE of Non Resident. 2. FFTS: where services giving rise to fee are rendered through PE of Non Resident. Such fee shall be treated as business income of PE of Non Resident. 3. Royalty or FFTS exempt from tax.
  • 50. 50 [S-2(54)] Royalty Royalty means any amount Paid Payable Periodical or lumpsum as consideration for following (vi) (vii) supply of any assistance ancillary and subsidiary to any property or right mentioned above disposal of any right or property mentioned above (v) Use or right to use Industrial/commercial/scientific equipment (iv) Supply of Technical/industrial/commercial/scientific Knowledge/skill (iii) receive or right to receive visual image or sound transmitted by Satellite/Cable Optic Fiber Similar technology in connection with Television Radio Internet broadcasting (ii) Use or right to use copyright or a literary, artistic or scientific work including films or video tapes for use in connection with television or tapes in connection with radio broadcasting but shall not include consideration for sale, distribution or exhibition of cinematograph films (i) Use or right to use Patent Invention Design Model Secret formula Process Trade mark Other like property/right
  • 51. 51 [S-2(23)] FFTS means any consideration, whether periodical or lump sum, for rendering : (b) consideration chargeable under head "Salary" (a) consideration for services in connection with construction, assembly or like project It does not include following Including services of technical or other personnel Managerial Technical Consultancy Services
  • 52. 52 [S-7] Tax on Shipping & Air Transport Business of Non-ResidentSeparate Block Non-Resident owns a ship or aircraft Tax shall be imposed @ 1st Sched, Part-I, Div-V Tax Imposed will be Final Tax On Gross Amount Passengers, live stock, mail, goods embarked In Pakistan Outside Pakistan Amount Received/Receivable In Pakistan P P Outside Pakistan P O
  • 53. 53 [S-7A] Tax on Shipping of Resident PersonSeparate Block Resident doing shipping business Ships flying Pakistan Flag @ 1 US $ per Gross Registered Tonnage Pay Tonnage Tax Ships not registered in Pakistan Pay Tonnage Tax 0.15 US $ per Gross Registered Tonnage For each voyage to Pakistan Subject to maximum of 1 US $ per Gross Registered Tonnage Exchange rate on following dates shall be applicable: i. In case of Company, 1st December of relevant Tax Year ii. In other cases, 1st September of relevant Tax Year Tax paid under this section shall be Final Tax This section shall not be applicable after 30.06.2020
  • 54. 54 [S-7C] Tax on BuildersSeparate Block Person deriving income from business of Construction & Sale of residential/commercial/other building @ 1st Sched, Part-I, Div-VIIIA Pay tax on basis of area of building constructed On business or projects initiated/approved after 01.7.2016 FHR may prescribe following: i. mode/manner for payment/collection of tax ii. Authority who will grant approval for computation and payment plan of tax iii. Responsibilities/powers of authorities who will approve/suspend/cancel NOC to sell the property
  • 55. 55 [S-7D] Tax on DevelopersSeparate Block Person deriving income from business of Development & Sale of residential/commercial/other Plots @ 1st Sched, Part-I, Div-VIIIB Pay tax on basis of area of Plot On business or projects initiated/approved after 01.7.2016 FHR may prescribe following: i. mode/manner for payment/collection of tax ii. Authority who will grant approval for computation and payment plan of tax iii. Responsibilities/powers of authorities who will approve/suspend/cancel NOC to sell the property