Islamabad, November 22, 2025 – The Federal Board of Revenue (FBR) has issued updated rules regarding individuals and entities not appearing in the Active Taxpayers List (ATL) for the tax year 2025.
According to FBR, only persons who have filed their income tax returns by the due date, or filed late with the payment of surcharge, will be included in the ATL.
The FBR issued the 10th Schedule of the Income Tax Ordinance, 2001, specifying detailed provisions for tax collection and deduction from persons not on the ATL. Under the updated rules, tax rates on transactions involving non-ATL persons are increased to discourage non-compliance.
Tax Rates for Persons Not Appearing in ATL (Section 236K)
| S. No. | Fair Market Value of Immovable Property | Tax Rate |
| 1 | Up to Rs. 50 million | 10.5% |
| 2 | Rs. 50 million to Rs. 100 million | 14.5% |
| 3 | Above Rs. 100 million | 18.5% |
Tax Collection on Other Transactions for Non-ATL Persons
| S. No. | Section | Description | Tax Rate |
| 1 | 236C | Sale/transfer of immovable property | 11.5% |
| 2 | 236G | Sale to distributors/dealers (excluding fertilizer) | 2% |
| 3 | 236H | Sale to retailers | 2.5% |
FBR also clarified rules for persons on the ATL who have not filed returns by the due date, imposing higher tax rates depending on the fair market value of property or consideration received. Provisional assessments may be made by the Commissioner if returns are not filed within the due period, with such assessments treated as final after 45 days unless returns or wealth statements are submitted within the timeframe.
The regulations require withholding agents to provide complete details of non-ATL persons, and failure to do so may result in penalties under sections 182 and 191. Moreover, the Commissioner retains the authority to amend assessments based on definite information, undisclosed income, or misclassification of income.
Certain exemptions are also defined, including taxes collected or deducted under specific sections like 149, 152 (certain clauses), 154, 154A, 231AB, 235, 236, and 237A. FBR emphasized that these measures aim to strengthen tax compliance and expand the active taxpayer base across Pakistan.