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Pakistan Corporate - Income determination

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Inventory valuation

Inventories are to be stated at the lower of cost or market. The first in first out (FIFO) and average methods are accepted. Conformity of methods used for book and tax reporting is desirable, and the method used should be consistently applied.

Capital gains

Capital gain on the sale of immovable property acquired on or after 1 July 2016, on which depreciation is not allowed, is taxed at the rate of 10% if disposed of within one year, 7.5% if disposed of within two years, and 5% if disposed of within three years. However, if the retention period is more than three years, such gain is not taxable. Capital gain on the sale of immovable property acquired before 1 July 2016 is taxed at 5% if disposed of within three years. No tax is payable if the retention period is more than three years.

Gain on the disposal of shares of a resident company or a non-resident company, whose assets wholly or principally consist of immovable property situated in Pakistan or rights to explore/exploit natural resources in Pakistan, shall be Pakistan-source income.

Tax rates on capital gains on the sale of shares of public companies, modaraba, and other specified ‘securities’ are exempt from tax if the date of acquisition of shares is before 1 July 2013. Capital gains on such instruments for tax years 2018 and 2019 are taxed as follows:

Holding period Tax rates - Filers (%) Tax rates – Non-filers (%)
Securities acquired before 1 July 2016 Securities acquired after 1 July 2016 Securities acquired before 1 July 2016 Securities acquired after 1 July 2016
Less than 12 months 15 15 18 20
12 months or more, but less than 24 months 12.5 15 16 20
24 months or more 7.5 15 11 20

Capital gain on future commodity contracts entered into by members of the Pakistan Mercantile Exchange is 5% for both filers and non-filers.

Capital gain, other than on statutory depreciable assets, realised within one year of acquisition is fully taxed; after one year, 75% of such gains are taxed and 25% are exempt.

Capital gains on statutory depreciable assets (other than immovable property) are chargeable to tax as normal business income in the year of sale. They are measured as the difference between the sale proceeds and the tax written-down value of the relevant asset sold.

In the case of an asset disposal transaction that is on a non-arm’s-length basis, fair market value of the asset shall be taken to be the consideration received by the seller, as well as the cost for the buyer.

Where assets are transferred outside Pakistan, the original cost is treated as the sale price, which means that the entire depreciation is recaptured at the time of export, except if the assets are used in oil or gas exploration, in which case only the initial depreciation is recaptured.

No gain or loss shall be taken to arise on disposal of an asset by a resident company to another resident company, provided certain conditions are met. The required conditions include, inter alia, that the transferor is 100% owned by the transferee or vice versa or both companies are 100% owned by a third company, and the transferee income is not exempt in the year of transfer. The scheme of arrangement is approved by the Securities and Exchange Commission of Pakistan or State Bank of Pakistan.

Any distribution to the shareholders of a company, to the extent that it relates to undistributed profits, is treated as a dividend.

Capital loss can be offset only against capital gains. Unabsorbed capital loss (except that arising on disposal of listed securities) can be carried forward for adjustment against capital gains for six years.

Capital gain derived on disposal of assets by non-residents outside Pakistan

Gain on disposal/alienation of any asset derived outside Pakistan by a non-resident person in respect of any asset located in Pakistan now constitutes Pakistan-source income.

With respect to shares of a company, however, the asset shall be treated to be located in Pakistan if:

  • the share or interest derives, directly or indirectly, its value principally or wholly from the assets located in Pakistan
  • the share or interest representing 10% or more of the share capital of the non-resident company is disposed or alienated, and
  • the share or interest, as mentioned above, derives its value principally from an asset located in Pakistan if on the last day of the preceding tax year the value of such asset exceeds PKR 100 million and represents at least 50% of value of total assets.

Where the entire assets of the non-resident company are outside Pakistan, a share or interest in such company will be treated as located in Pakistan to the extent of reasonable attribution.

The above gain is subject to income tax (with no further incidence of tax under any other provisions of law) at the higher of:

  • 20% of the amount representing the difference between fair market value and cost of acquisition of the asset, or
  • 10% of the fair market value of the asset.

Dividend income

Dividend income is subject to tax/WHT of 15% or a lower tax treaty rate. A rate of 20% is applicable for persons receiving dividend income but not filing income tax returns (non-filers).

The deduction at source shall be the full and final discharge of tax liability on dividend income. However, in case of non-filers filing a return of dividend income, they will be entitled to a refund of 5% of the 20% tax withheld on dividend income (over and above the applicable tax charging rate of 15% on such dividends).

Interest income

Interest earned by a company is taxed as its income from other sources. Interest earned by a non-resident company without a PE in Pakistan attracts WHT at the rate of 10%, except where a lower rate is provided in the related DTT, which is also the final tax on such income.

Income from royalties and fees for technical services/offshore digital services

Royalties received by non-residents are deemed to accrue or arise in Pakistan and are taxable if paid by a resident in Pakistan or borne by a PE of a non-resident in Pakistan.

Income from ‘fees for technical services’ and ‘fees for offshore digital services’ are deemed to accrue or arise in Pakistan if paid by a resident in Pakistan or borne by a PE of a non-resident in Pakistan.

‘Fees for technical services’ means any consideration for the rendering of any managerial, technical, or consultancy services (including the provision of the services of technical or other personnel), but does not include consideration for any construction, assembly, or like project undertaken by the recipient or consideration that would be income of the recipient chargeable under the head salary.

‘Fee for offshore digital services’ means consideration for rendering or providing services of online advertising and online collection of data processing or any facility for online sale of services.

Other significant items

Liabilities allowed as a tax deduction in a tax year and remaining unpaid for three subsequent years are deemed to be income in the first tax year following the said three years. Such items are then allowed as a deduction in the year the liability is discharged.

Agricultural income is exempt from income tax.

Foreign income

A resident company is taxed on its worldwide income and on its foreign income as earned. Double taxation of foreign income is avoided by means of foreign tax credits; this relief is allowed to the resident company on the doubly taxed income at the lower of the Pakistan or foreign tax rate.

Foreign loss can only be offset against foreign income and can be carried forward for six years.

Modaraba

Modaraba (profit sharing) is a financing vehicle that enables a management company to control and manage the business of a modaraba company with a minimum of 10% equity participation. The management company is entitled to remuneration based on an agreed percentage (but not exceeding 10%) of annual profits of the modaraba business. A modaraba can be for a specific purpose or many purposes and for a limited or unlimited period. The income of a modaraba not relating to trading or manufacturing activity is exempt from tax if 90% of its profits are distributed as cash dividend.


Last Reviewed - 30 June 2018

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