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11 August 2025
Author: Asif S Kasbati (FCA, FCMA & LLB)
I. High Level professionals: Mr Abid Shaban - Member Tax Reform Implementation Commission & Mr Ayaz Mehmood - Ex Tribunal Member
II. Subscribers: Mr Shariq - CFO at Equant Pvt Ltd
A. Background (BG)
1. This refers to the related Important COQCs in trail, blue, italic and double line (a) 342 of 19.8.19 about Updated "Employees Contributory Funds (Investment in Listed Securities) Regulations" (b) 333 of 30.7.19 about Amendments in Employees Contributory Funds Regulations, 2018 - SRO 856
2. We also refer to several Other QC including 321 of 29.4.19 about 7 amendments in Employees Contributory Funds Regulations, 2018 - SRO 491
B. Updated Commentary
We would inform you about Employees Contributory Fund (Investment in Listed Securities) Regulation (Attachment 652.1) in the ensuing paragraphs.
2. As per Regulation 5 of the Employees' Contributory Funds (Investment in Listed Securities) Regulations, 2018, all companies are required to submit financial information of their Provident or any other contributory fund or Trust to the Commission within one month after the close of each six-month period of the financial year.
3. It has been observed by SECP that several companies have not complied with this requirement. Please note that failure to file the said information is an offence under Section 219 of the Companies Act, 2017.
4. Mandatory Disclosures of (a) Mandatory disclosures regarding Investment out of Fund or Trust (b) Break-up of Cost of Investment out of Fund or Trust is given Annexure A to the SECP email (Attachment 652.1).
5. Therefore, all companies are advised to ensure compliance with the provisions of Employees' Contributory Funds (Investment in Listed Securities) Regulations, 2018 and electronic filing (e-services) of information relating to the funds.
C. Kasbati & Co Clarification (KCC)
In view of the above, if year-end is say 30.6.25 the Bi-annual Financial Information for 31.12.24 & 30.6.25 was to be submitted by 31.1.25 & 31.7.25 respectively. For the year-end say is 31.12.24, the Financial Information for 30.6.24 & 31.12.24 was required to be filed by 31.7.24 & 31.1.25 respectively.
D. Further Details & Services
Should you require any clarification or explanations in respect of the above or otherwise, please feel free to email Mr Amsal at amsal@kasbati.co with CC to info.kasbati@professional-
Best regards for Here & Hereafter
Asif S Kasbati (FCA, FCMA & LLB)
Managing Partner
Kasbati & Co (1400+ Tax, Levies, Companies, Economy, Inflation, HR, Banking, Finance, etc
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