SOHAIL SARFRAZ

ISLAMABAD: The government has introduced first of its kind of Finance Bill 2025-26 with extraordinary enforcement measures against non-filers and taken new taxation/enforcement measures of over Rs623 billion including tax on payments for digital transactions in e-commerce platforms, increase in withholding tax rate on sales of immovable properties and withdrawal of sales tax exemption on erstwhile tribal areas in phases to meet assigned target of Rs14,131 billion for 2025-26. Breakup of taxation measures revealed that out of Rs670 billion taxation measures, the revenue loss on account of relief provided to the salaried class of Rs58 billion. The net revenue impact of taxation measures stood at Rs623 billion including both tax and enforcement measures.

There are taxation and enforcement measures of Rs281 billion and Rs389 billion respectively, resulting in total revenue of Rs670 billion. Following exclusion of relief measure of Rs58 billion, the net increase in revenue measure will generate revenue of Rs623 billion in the next fiscal year.

The FBR did not arrange the traditional technical briefing on the Finance Bill and the new taxation measures for journalists due to unspecified reasons.

Under the Finance Bill 2025-26, the government has imposed restriction on economic transactions by ineligible persons (non-filers) including bar on purchase of motor vehicles, immovable property, sale of securities including debt securities or units of mutual funds and banks would not allow non-filers to open or maintain an already opened current or a saving bank or investor portfolio securities accounts and also not allow cash withdrawal from any of the bank accounts. Sales tax exemption to Special Economic Zone (SEZ) and Special Technology Zone (STZ) entities, developers has been restricted to tax year 2035 or expiry of 10 years exemption period, whichever is earlier.

Major changes have been proposed in the withholding tax regime including increase in withholding tax from 0.6 percent to one percent on cash withdrawals by non-filers.

The withholding tax rate increase for specified services from four per cent to six per cent with the exception of IT and IT enabled Services has been proposed. For other non-specified services, a flat 15 per cent will be imposed and from 10 per cent to 15 per cent on sportsperson.

The Finance Bill 2025-26 revealed on Tuesdaya tax of two per cent of gross value of supplies, persons supplying digitally ordered goods from within Pakistan through online market place.

The FBR has imposed 18 percent sales tax on the import of solar panels/PV modules. The FBR has also withdrawn reduced rate of 12.5 per cent is chargeable on supply of locally manufactured or assembled motorcars up to 850cc.

The imported pet food including “dogs and cats” food in retail packing, coffee in retail packing, chocolates in retail packing and imported cereal bars in retail packing have been included in the list of items under Third Schedule of the Sales Tax Act, 1990, based on the retail price at applicable rates as embossed on the packaging of the product.

Currently, supply of electricity to residential, commercial and industrial units located in erstwhile FATA/PATA is exempt till 30.06.2025. In order to provide relief to electricity consumers in these areas, it is proposed that above-mentioned exemption may be extended till 30.60.2026.

Currently, reduced rate of 10 per cent is available on local supply of vermicellis and sheer mall. As part of the GST reforms, all existing concessionary rates are reviewed and withdrawn wherever possible. Therefore, reduced rate of 10 per cent is proposed to be withdrawn.

Bun and rusk are currently subject to a reduced 10 per cent sales tax. Since they are staple foods for lower-income groups, it is proposed that their local sale be exempted from sales tax.

On income tax side, “Digital Transactions Proceeds Levy” has been introduced along with necessary changes in the Income Tax Ordinance, 2001 to cover domestic vendors supplying digitally ordered goods and digitally delivered services. Banks and courier services designated as withholding agents to capture entire payment chain.

Provisions regarding assessment of banking companies has been made more disclosure oriented to determine true and fair income of the banking companies and tax payable thereon.

Tax rate on profit on debt has been proposed to be increased from 15 per cent to 20 per cent. The dividend tax rate has been enhanced to 25 per centand 15 per cent on dividend from mutual funds. Pension income received by an individual below the age of 70 years and over and above of Rs10,000,000 has been charged to tax at the flat rate of five per cent.

Super tax rates under Section 4C proposed to be reduced by half a percentage point for income slabs between Rs200 million to Rs500 million against each slab respectively.

Tax rates for salaried individuals for income slab upto Rs3,200,000 has been reduced to provide relief to lower and middle tiers income bracket.

Similarly, surcharge rate proposed to be reduced from 10 per cent to nine per cent for salaried individuals only. Income tax exemption along with withholding tax exemption for erstwhile FATA/PATA areas propose for extension for one year i.e. upto TY 2026. 25 per cent rebate against tax payable by full time teachers and researchers will be restored retrospectively i.e. from TY 2023 to TY 2025. Proportionate tax credit to on profit on debt on loan obtained for construction or acquisition of a house of 250 sq. yd. and a flat having 2,000 sq ft. or less area.

To better incorporate digitally ordered taxable goods into the e-commerce sales tax framework, the definition of “e-commerce” has been introduced, and “online marketplace” is redefined to include all taxable activities. Currently, online marketplaces are required to withhold one per cent sales tax on local supplies made by non-active taxpayer vendors. However, this does not fully capture the growing e-commerce sector, especially businesses using websites, apps etc for online sales to consumers. To address this, the withholding tax scope has been expanded to cover transactions settled via online payment or CoD. Under the proposed regime — substituting S No 8 of the Eleventh Schedule — payment intermediaries (banks, financial institutions, exchange companies, and payment gateways) will collect sales tax on digital payments, while couriers will handle tax collection for CoD transactions. Additionally, the withholding tax rate is set to increase from one per cent to two per cent.

Importers and manufacturers are required to collect sales tax on items listed in the Third Schedule of the Sales Tax Act, 1990, based on the retail price at applicable rates as embossed on the packaging of the product. The purpose of the inclusion in the Third Schedule to capture the down-stream value addition in the supply chain beyond manufacturing.

Currently, supply of electricity to residential, commercial and industrial units located in erstwhile FATA/PATA is exempt till 30.06.2025. In order to provide relief to electricity consumers in these areas, it is proposed that above-mentioned exemption may be extended till 30.60.2026.