PTBA raises concerns over FBR’s electronic invoicing, integration system

KARACHI: The Pakistan Tax Bar Association (PTBA) has expressed serious reservations regarding SRO 69(I)/2025, issued by the Federal Board of Revenue (FBR) to regulate licensing, electronic sales tax invoicing and the integration of registered businesses.

In a letter to the FBR chairperson, the PTBA voiced its disappointment over the outcome of the point-of-sale (POS) integration scheme, introduced two to three years ago, which it said failed to achieve full implementation. The new SRO, the PTBA noted, outlines procedures for licensing, issuing electronic sales tax invoices, and integrating registered businesses, while also detailing the consequences of non-compliance.

“We believe that rules 150X, 150XD, 150XF, 150XI, 150XJ, 150XN, 150XP, and 150XQ need to be implemented with caution. In the past, abrupt actions by the FBR led to ineffective enforcement, causing reputational damage to businesses, and ultimately failing to hold up in appeals,” the PTBA said. The association recommended that registered businesses should be notified immediately, with clear procedures and reasonable timelines to facilitate compliance.

The PTBA further stressed that the newly classified registered businesses under this SRO must be treated uniformly. It warned that inconsistent implementation would render the regulation ineffective, diminishing its credibility among non-filers and allowing business operations to continue as usual without enforcement.

The body also urged that any action, raid or notice issued against taxpayers must be evidence-based and legally sound to withstand scrutiny in appeal processes, thereby ensuring that enforcement measures contribute effectively to revenue collection.

The PTBA highlighted the need for a simple and cost-effective integration process, arguing that taxpayers are already burdened with significant compliance costs. It suggested allowing businesses to integrate through their existing IT consultants, as was permitted during the POS system rollout, enabling seamless connectivity with the PRAL server.

The PTBA also proposed scrapping the licensing process, arguing that it could lead to malpractice and harassment. It pointed out that with the implementation of POS and electronic invoicing, FBR already has real-time access to taxpayers’ financial data, making additional licensing requirements unnecessary.