468+ Taxes & Levies Quick Commentary (TLQC) 2632

A.   Background

This refers to following TLQCs (in trail, blue, italic and after double line):

(a)   2605 of 12.1.24 about FMCGs Supply Chain to issue ST Invoices Electronically vide SRO 28 of 10.1.24.

(b)   2573 of 15.12.23 about EIS / POS Rules Changes Analysis vide SRO 1788

(c)   2571 of 13.12.23 about FMCGs Importers, Manufacturers & Trader EIS/POS about SRO 1525-DI of 12.12.23 inter alia covering effective or not.

(d)   2543 of 18.11.23 about POS Rules Changes vide SRO 1525 dated 10.11.23 Analysis.

B.   Updated Commentary

You may recall from our TLQC 2543 (in trail) that FBR vide SRO 1525 of 10.11.23 made further Amendments in the ST Rules including substitution of Rule 150R which deals with Eligibility to use electronic invoicing system. The substituted Rule 150R is reproduced below in Italic for ready reference with emphasis ours in bold:

150R. Eligibility to use electronic invoicing system.-- (1) A registered person, notified under rule 150Q, hereinafter referred to as the integrated supplier in this Chapter, shall install electronic invoicing system provided by a person, licensed under Chapter XIV-BB of the Sales Tax Rules, 2006.

(2) No sale or supply by an integrated supplier shall be made without being recorded in the electronic invoicing system.

2.   Moreover, you may also recall from our TLQC 2573 (in trail) that FBR vide SRO 1788 dated 11.12.23 made Amendments in ST Rules pertaining to Tier-I Retailers including Rule 150ZQZH which deals with Licensing for Integration of the Registered Persons, including Tier-I Retailers. The updated Rule 150ZQZH is reproduced below in Italic for ready reference with emphasis ours in bold:

150ZQZH. Licensing. (1) No person shall carry out integration of the registered persons, including tier-I retailers, through software unless he has obtained a license under these rules.

(2) No licensee under these rules shall maintain or operate system or provide any other service, which is not authorized under these rules. 

(3) Every payment counter whether fixed or portable and generates invoices for receipt of payment either in cash or through debit or credit card shall be integrated with the Board through the system accredited and licensed by the Board.

3.   Further to above TLQCs & KQU 2649 of 3.2.24, being an Important matter, we would inform you about FBR Clarification regarding Digital Invoicing on FBR DIS (Attachment 2632.1).

4.   To provide Facilitation and mitigate the Hardships faced by the Registered Persons, it is intimated that until the Licensed Integrators are notified by FBR, Registered Persons notified vide SRO 28 dated 10.1.24 (TLQC 2605 in trail refers) shall integrate their Electronic Invoicing System (EIS) with the FBR Digital Invoicing System (FDIS) as already available on FBR’s website without Licensed Integrators.

C.   Further Details & Services

Should you require any clarification or explanations in respect of the above or otherwise, or require Income Tax, Federal & Provincial Sales Tax or Withholding Tax Advisory, Statement or Return Filing or Review services, or related accounting matters like the above, please feel free to email Mr Amsal at amsal@786tax.com with CC to info.kasbati@professional-excellence.com. Your Goodself may continue to get other services from your current Tax & Legal Advisors.