The Pakistan Tax Bar Association (PTBA), a leading voice for tax professionals in the country, has raised significant concerns regarding a newly introduced tax regulation, Statutory Regulatory Order (SRO) 69(I)/2025. Issued by the Federal Board of Revenue (FBR) on January 29th, 2025, SRO 69 aims to implement new procedural guidelines affecting business licensing, electronic invoicing, and the integration of taxpayers into the national tax system.
In a formal communication directed to the FBR Chairman, the PTBA outlined several key areas of apprehension. The association expressed worries about the practical implications of these new rules, particularly concerning licensing procedures, the mandated shift to electronic invoicing, and the overall process of bringing registered taxpayers into closer integration with the FBR’s systems.
The PTBA emphasized that while they acknowledge the FBR’s objective of improving supply chain documentation, they believe the current approach in SRO 69 carries considerable risks. Having conducted a thorough review of the regulation and its potential consequences, the tax body has put forth a series of recommendations intended to bolster compliance and simultaneously protect the interests of law-abiding taxpayers.
Drawing upon past experiences, the PTBA highlighted the unsuccessful implementation of previous initiatives, such as the Point of Sale (POS) integration system. They argued that the ineffective rollout of such programs has eroded trust between the taxpaying community and the FBR. This historical context, they suggest, underscores the need for a more cautious and considered approach to SRO 69.
Specifically, the PTBA urged the FBR to exercise restraint in enforcing the procedural requirements detailed in SRO 69, particularly rules 150X through 150XQ. They cautioned against replicating past instances where abrupt and forceful enforcement actions by FBR officials led to legal challenges and damaged the reputations of businesses diligently adhering to regulations. To ensure smoother implementation and broader compliance, the PTBA stressed the critical need for proactive and clear communication. They recommended that all registered individuals and businesses receive timely notifications and easily understandable, simplified guidelines to facilitate their adherence to the new rules.
To mitigate the financial burden on taxpayers, the PTBA proposed streamlining both integration and licensing procedures. A key suggestion was to permit businesses to utilize their existing IT consultants for integration with the FBR’s PRAL system. This approach, they argued, would lessen reliance on external licensing bodies, potentially reducing costs and curbing opportunities for corruption and undue harassment.
Furthermore, the PTBA advocated for a re-evaluation of routine sales tax audits in light of the new electronic invoicing system. With real-time transaction monitoring becoming a reality through electronic invoicing, they contended that traditional audits would represent an unnecessary burden on businesses. Continuing standard audits, they warned, would increase compliance costs, further strain the taxpayer-FBR relationship, and erode trust in the tax administration.
While reaffirming its support for initiatives aimed at expanding the national tax base, the PTBA underscored the paramount importance of transparent and taxpayer-friendly implementation strategies. They cautioned that inconsistent enforcement of SRO 69, or the perception of preferential treatment towards certain businesses, could undermine the regulation’s effectiveness and potentially encourage continued non-compliance.
In conclusion, the Pakistan Tax Bar Association has issued a strong call to action for the FBR to address these identified concerns without delay. They urged the revenue authority to ensure that the implementation of SRO 69 fosters a tax environment characterized by fairness, efficiency, and the absence of harassment. The PTBA emphasized the necessity of open dialogue and collaborative efforts between the FBR and the taxpaying community to build confidence and ultimately enhance revenue collection for the benefit of Pakistan’s national development.
