Karachi, February 14, 2025 – The Pakistan Tax Bar Association (PTBA) has voiced significant apprehensions regarding the introduction of SRO 69(I)/2025, issued by the Federal Board of Revenue (FBR) on January 29, 2025.
In a formal communication addressed to the FBR chairman, the PTBA highlighted various concerns about the implications of the new procedural guidelines for licensing, electronic invoicing, and integration of registered taxpayers.
The PTBA, after thoroughly reviewing the contents and potential outcomes of SRO 69(I)/2025, has recommended several measures to improve compliance while safeguarding the interests of honest taxpayers. The association acknowledged the FBR’s efforts to document the supply chain but emphasized that past initiatives, such as the Point of Sale (POS) integration, were not implemented effectively, leading to a lack of trust within the taxpayer community.
According to the PTBA, the procedural requirements outlined in SRO 69(I)/2025, including rules 150X to 150XQ, must be enforced cautiously. The association expressed concern about past instances where abrupt enforcement actions by FBR officials resulted in legal setbacks and damaged the reputation of compliant businesses. The PTBA stressed that all registered persons should be promptly notified and provided with clear, simplified guidelines to facilitate compliance.
The PTBA also recommended that integration and licensing procedures should be streamlined to minimize costs for taxpayers. They proposed allowing businesses to integrate with the FBR’s PRAL system using their existing IT consultants, a step that would reduce dependency on external licensing bodies and curb opportunities for malpractice and harassment.
Furthermore, the PTBA suggested abolishing routine sales tax audits, given that the new electronic invoicing system provides real-time transaction monitoring. They argued that continuing with standard audits would impose unnecessary burdens on businesses, increase compliance costs, and erode trust in the tax administration.
The PTBA reiterated its commitment to supporting initiatives aimed at broadening the tax base but stressed the importance of transparent, taxpayer-friendly implementation. The association warned that inconsistent enforcement or preferential treatment of certain businesses could undermine the effectiveness of SRO 69(I)/2025 and perpetuate non-compliance.
In conclusion, the PTBA called on the FBR to address these concerns promptly, ensuring that the new regulations foster a fair, efficient, and harassment-free tax environment. The PTBA emphasized the need for open dialogue and collaborative efforts to build taxpayer confidence and enhance revenue collection for national development.