The Pakistan Federal Board of Revenue (FBR) released two significant notifications at the end of 2023 that will require electronic sales tax invoices to be issued for certain consumer goods.

A 10 November 2023 notification introduced substantial amendments to the special procedures for the issuance of electronic sales tax invoices between buyers and sellers. These changes fall under Chapter XIV of the Sales Tax Rules, 2006 (ST Rules).

Correspondingly, on 12 December 2023, the FBR released a notification specifying importers, manufacturers, wholesalers (including dealers) and distributors of "fast-moving consumer goods" as the "prescribed persons" to issue and transmit electronic sales tax invoices. "Fast-moving consumer goods" are defined as products supplied in retail marketing as per daily consumer demand (excluding durable goods).

A summary of key amendments follows.

• The rules apply to all registered persons prescribed and notified by the FBR from a specific date.
• The FBR has not yet established the date for implementing these rules with prescribed persons.
• Prescribed persons will install an "electronic invoicing system" provided by an FBR-licensed person.
• Integrated suppliers will issue real-time, verifiable electronic sales tax invoices for every taxable supply in accordance with the information required under section 23 of the Sales Tax Act, 1990 (ST Act).
• Integrated suppliers will permit both physical and online remote access to the records, systems, logs and documents maintained in electronic form as needed by the FBR's prescribed officer.
• Prescribed persons will face penalties for noncompliance with these rules. However, they may continue to issue paper invoices if the Commissioner of Inland Revenue grants them permission.
• The aforementioned conditions and requirements will also apply to registered buyers who receive electronic invoices from integrated suppliers.

Implications

In light of the new notices, manufacturers, importers, wholesalers and distributors of fast-moving consumer goods will need to incorporate the FBR's system to issue electronic sales tax invoices. However, the implementation date remains to be announced. Moreover, it seems that the same requirement for system integration with FBR also applies to registered buyers who receive electronic invoices from integrated suppliers.

Note that this Tax Alert is general in nature and is not a substitute for detailed research or the exercise of professional judgment. Accordingly, no decision on any issue should be taken without seeking specific professional advice and further consideration.