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02/12/2021

The Federal Board of Revenue (FBR) has jacked up the valuation rates of FBR-notified rates of immovable property, including commercial, residential, apartments, flats and other areas of 40 selected major cities of the country.

The FBR used to fix immovable property rates of 20 selected cities but now this number has increased to 40 major cities, while areas within the cities have also increased. So, the coverage of valuation tables increased.

The valuation tables have been revised upward with the aim to collect more taxes from the property sector. The FBR has increased the valuation rates of selected 40 cities manifold.

01/07/2021

ISLAMABAD:The Federal Board of Revenue (FBR) has collected Rs4.725 trillion in taxes in the last fiscal year at a healthy growth rate of 18%, which is better than expectations but lower than the original unrealistic tax target.

Unlike in the past when it used to take huge advances and block refunds, this time the machinery did not use arm-twisting measures and instead relied on enforcement tools that helped it still to show double-digit growth.

During fiscal year 2020-21 that ended on Wednesday, the FBR collected Rs4.725 trillion – up by Rs727 billion or 18% over the collection in the preceding year, said the provisional figures compiled by the FBR.

However, the collection fell short by Rs238 billion against the original target of Rs4.963 trillion set at the start of the fiscal year.

During his post budget press conference, former finance minister Dr Abdul Hafeez Shaikh had appealed to the provinces that they should make their budgets on realistic assumptions as the Rs4.963 trillion target might not be achieved.

It was the third consecutive year that the FBR missed the original target due to setting targets under assumptions that were beyond the FBR’s control. Cumulatively, the PTI government collected Rs2.4 trillion less than the targets it set during its first three years in power.

Setting unrealistic targets also costs the cash-starved federal government since Balochistan gets its 9.09% share in the federal divisible pool on the basis of the original target instead of the actual collection.

All the three provinces will get their shares on the basis of Rs4.725 trillion and Balochistan will get on the basis of Rs4.963 trillion.

Independent economists and tax experts had been predicting that against the original target of Rs4.963 trillion, the FBR would generate Rs4.5 trillion to Rs4.6 trillion. But 18% growth in revenues has remained better than these expectations.

“The last fiscal year remained phenomenal as the FBR had remained successful in clearing all the income tax and sales tax refunds claims that were filed within the fiscal year 2020-21,” said FBR Nember Inland Revenue Operations Dr Mohammad Ashfaq.

Ashfaq maintained that only previous fiscal years (2007 to 2019) refunds were pending.

In fiscal year 2020-21, the FBR had paid Rs251 billion in refunds, which were 85% higher than the preceding year. These include Rs209 billion sales tax refunds.

Due to release of refunds, the companies’ working capital requirements were reduced, which helped them to finance their operations without taking loans, said member operations.

He said in the past the refunds were used as a tool to increase collection “but we can say with confidence that no sales tax refund is pending in the FBR’s system that pertains to just ended fiscal year”.

“The Rs4.725 trillion is clean money and neither the FBR took advances nor it blocked taxpayers’ refunds,'' Dr Ashfaq said. “There were another Rs75 billion refunds that had been adjusted against the demand.”

Due to reliance on post-refund audits, the FBR has also been able to neutralize Rs114 billion refunds’ claims, which gave a signal to the exporters that where the FBR was active in giving refunds, it was also vigilant on bogus refund claims, said the member operations.

Ashfaq said the FBR’s strategy to shift 350 big cases to the large tax offices from small field formations would help get due taxes from these individuals. It is for the first time that taxation policies have helped strengthen people's confidence in the state, he added.

However, all was not well on the taxation front due to increasing collection at the import stage and growing reliance on indirect taxes, which remained the two distinctive features of the FBR’s revenue performance in the last fiscal year.

The Indirect taxes have also contributed to higher prices, including those of sugar and edible oil

03/06/2021

ISLAMABAD: The government plans to get additional revenues of Rs480 billion in the upcoming budget through abolishing Income Tax and Sales Tax exemptions and improved administrative measures in order to materialize the FBR’s desired target of Rs5,800 billion.

However, ironically the Islamabad Capital Administration has slashed down property valuation rates in the federal capital instead of jacking it up to bring them at par with the market rates.

There will be slight adjustments in major taxes with the purpose to streamline the taxation system as the number of salaries slabs would be brought down, rental income would be adjusted, two dozen withholding taxes would be abolished, Point of Sale (POS) machine would be installed at 85,000 branded chains in urban centers with 12 percent for textile and 14 percent GST for other sectors and discretionary powers of tax officials would be curtailed to restore confidence of taxpayers.

According to fiscal framework agreed with the IMF, the FBR’s target for the next budget was envisaged at Rs5,800 billion on the basis of revenue collection of Rs4,700 billion achieved in the outgoing fiscal year.

With nominal growth of 13.2 percent including real GDP growth rate of 5 percent and inflation at 8.2 percent, the FBR revenues could be increased to Rs5,320.4 billion. Now the remaining Rs480 billion will have to be collected through abolishing tax exemptions, upward adjustment in taxes in a few selected cases such as increasing tax burden for higher income slabs, rental income and abolishing withholding taxes by around two dozen, bringing down tax burden on telecom sector and slashing down tariff on import tariff lines in the coming budget. The government has estimated that doing away of income tax and sales tax exemption would bring Rs140 billion taxes into the national kitty.

When contacted, former chairman FBR Shabbar Zaidi on Wednesday said that it would be hard for the FBR to collect Rs4,700 billion in the outgoing fiscal year and it could hardly go up to Rs4,500 to Rs4,600 billion maximum. He said that there was a dire need to ensure enforcement of CNIC condition for buyers and its limit could be increased to Rs0.5 million to Rs one million. This condition applies to Rs100,000 purchase of goods on buyers. The former chairman FBR said that abolishing income tax and sales tax exemptions would bring a meager tax collection but instead of discussing the next budget target, the FBR would have to strive for achieving the outgoing fiscal year’s target.

The official sources said that the government also plans to introduce third party audit from the next fiscal year. One FBR official termed it as old wine in a new bottle and said that it was an old concept of undertaking audit by chartered accountant firms, which had failed many years ago. It was stopped because it had failed to yield any desired results. “If this is the idea, then it is like disbanding the revenue agency when you have no trust in it. It is required to improve internal controls to ensure that discretionary powers are used judiciously. Who would bother to comply if top functionaries of government possessed such low trust in your tax machinery?” He added the FBR possessed all relevant data and these facts could be checked before enforcement of old ideas.

21/04/2021

KARACHI: Government is resisting a proposal by the International Monetary Fund to cream off an additional Rs176 billion in tax revenue from salaried class in the upcoming budget for fiscal year 2021/22, people familiar with the matter said on Tuesday.

The sources said various tax rates are under consideration to boost the salary income tax collection from existing Rs129 billion to Rs305 billion.

That would make an additional Rs176 billion. The International Monetary Fund (IMF) had proposed the government to increase the revenue collection from salaried persons to Rs305 billion from existing Rs129 billion, in order to create room for development expenditures and reduce budget deficit, according to the sources.

The revenue collection from salary income increased to Rs129.4 billion the during fiscal year 2019/20 from Rs76.4 billion in the preceding fiscal year, showing an increase of 70 percent.

The sources said the Federal Board of Revenue (FBR) raised objections to the proposal of the IMF to increase salary tax collection to Rs305 billion. The FBR in its counter proposal suggested an increase of up to Rs10 billion in tax collection from salary income.

An official of the FBR said the tax authorities are opposing any significant increase in tax rates for salaried persons in the upcoming budget due to high inflation.

The official said the Prime Minister Imran Khan met with the IMF officials and asked the fund to soften the conditions on energy prices and taxes especially on education, health and agriculture sectors.

The IMF projected the revenue collection of the FBR at Rs5.9 trillion for fiscal year 2021/22 from an expected collection of the current fiscal year at Rs4.6 trillion, an increase of 27 percent. IMF has resumed $6 billion loan program for Pakistan after one-year pause.

Pakistani authorities had agreed with the IMF to simplify and increase personal income tax.

It was agreed to change the existing tax rate structure by reducing the number of rates and income tax brackets from eleven to five and decreasing the size of the income slabs, with a view to simplifying the system and increasing progressivity.

It was also agreed to reduce tax credits and allowances by 50 percent (except for zakat and those provided for disabled and senior citizens).

The authorities pledged to introduce a special tax procedure for very small taxpayers, aimed at preventing further tax base erosion and facilitating the formalization of the economy besides adopting a long-term strategy to reduce labor informality and to bring additional taxpayers into the personal income tax net.

The authorities estimated that the reform was expected to yield 0.4 percent of GDP on an annualised basis.

16/04/2021

ISLAMABAD: The Federal Board of Revenue is contemplating different options to bring down the number of slabs for personal income tax from 11 to 5 in line with the UK model during the upcoming budget 2021-22.

Top official sources confided to The News in background discussions that the government plans to introduce reforms in personal income tax in line with the IMF programme whereby the burden of tax payment would be decreased on lower-income ceiling earning Rs600,000 per annum while tax incidence would be increased on those who are earning over Rs300,000 per month basis.

“The FBR has estimated that it is going to collect Rs125 billion on account of PIT in the outgoing fiscal year 2020-21 but after the introduction of reforms in the next budget, the revenue collection can go up to Rs150 billion in 2021-22,” a top official disclosed while talking to The News in background discussions here on Thursday. The FBR had collected Rs116 billion on account of personal income tax in the last fiscal year 2019-20.

The FBR, which is in the process of firming up different taxation proposals, has so far decided that the taxable exemption ceiling for salaried class will be retained at Rs600,000 limit on annual basis in the next budget.

The IMF staff report described the planned reform of personal income tax by stating that it will simplify the system, increase progressivity and support labor formalization. It will reduce the number and decrease the size of the current income slabs, halve current tax credits and allowances (except those for disabled and senior citizens, and Zakat receipts), introduce special tax procedures for very small taxpayers and bring additional taxpayers into the net. The IMF Staff urged the authorities to also follow through with the completion of the reform and harmonization of general sales and personal income taxation in the FY2022 budget as they are key milestones to improving the tax system and place debt firmly on a downward path while making space for much-needed social and development spending.

In this connection, the FBR is working out different options and comparing the existing tax slabs structure with the proposed slabs having reduced brackets of five for both the salaried individuals and business individuals. The FBR has so far rejected any proposal to hike the tax rates for all slabs as it wants to burden those who are making lofty earnings, so the burden of tax incidence will be shifted on those shoulders who are earning more income on monthly basis.

When contacted, a former FBR official and tax expert Shahid Hussain Asad said that there was no need to replicate the model of other developed countries because they had devised slabs keeping in view their ground realities. He said that the basic exemption for tax would be appropriate at 1,200,000 per annum. He suggested that the tax slabs should be widened for income upto Rs3,600,000 per annum. However, the tax incidence can be increased on those who are earning Rs300,000 per month or more, he concluded.

06/03/2021

FBR Allows Tourists to Import Vehicles Without Duties for 6 Months

The Federal Board of Revenue (FBR) has changed the definition of ‘tourists’ for allowing temporary import of vehicles by tourists without payment of duties and taxes for a period of six months.

The FBR has proposed amendments in the Customs Rules 2001 through a notification issued here on Friday.

According to the SRO.201(I)/2021, the “tourist” means a person not normally resident in Pakistan, who enters Pakistan for a stay of not more than six months in the course of any twelve months period for legitimate non-immigrant purpose.

Previously, the definition of the tourist as per customs laws is that a tourist” means a foreigner of any of the following categories who has no residence or occupation in Pakistan and whose stay in the country is not likely to exceed three months:

A person visiting Pakistan for recreation or sight-seeing or is in transit for a short duration;
A person travelling for domestic or health reasons;
A person on study or lecture tour or on pilgrimage;
A person travelling in his individual or representative capacity to attend a meeting or function of any scientific, administrative, educational, social, cultural sports or religious nature or for giving a performance;
A person travelling for business purposes;
A person arriving in the course of a sea cruise whose stay in Pakistan exceeds 24 hours.
Under the procedure, a tourist who imports a vehicle against carnet-de-passage or a bank guarantee may be given delivery thereof by the officer-in-charge of the Customsstation of entry without payment of customs-duties for its retention in Pakistan if such tourist makes a declaration at the Customs-station of entry to the effect that he will not constructively or substantially transfer the ownership of the vehicles to any other person during his stay in Pakistan.

Provided that if it is not practicable for the tourist to export such vehicle within the said period and he makes an application to the FBR before the expiry of that period to this effect, the Board may extend that period not exceeding three months: Provided further that if the same vehicle re-enters Pakistan within one year after its exit, whether in the name of the same tourist (non-Pakistani) or in the name of somebody else (non-Pakistani) temporary release shall not be allowed against carnet-de-passage or a bank guarantee for more than fourteen days except for vehicles operated by recognized foreign tour agencies which shall be allowed re-entry within one year for a period not exceeding three months at one point of time.

Where the export of such vehicle is not possible on grounds of the health of the importer, or in circumstances beyond his control, or because of an accident in which the vehicle is involved, the FBR may extend the period not exceeding six months, in which case a fresh bank guarantee shall be furnished if the existing bank guarantee does not cover the period of extension: Provided that if the importer wishes to retain such vehicle beyond the period for which permission for retention has been allowed, he shall obtain an import permit from the Ministry of Commerce and shall pay the Customs-duties and taxes leviable thereon on the date of its import.

If a tourist imports a vehicle for passage through Pakistan to a foreign destination, the officer-in-charge of the Customs-station of entry may, in the absence of carnet-de-passage or a bank guarantee, allow the vehicle to pass through Pakistan without payment of customs duties under es**rt form the Customs-station of entry to the Customs-station of exit on payment of es**rt charges to be determined by the respective Collector. The particulars of the vehicle so allowed to pass through Pakistan shall be endorsed on the passport of the importer.

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16/02/2021

Super tax made permanent for banks:

The levy of super tax has been made permanent for banking companies beyond Tax Year 2021, sources in Federal Board of Revenue (FBR) said on Monday.

Tax Laws (Amendment) Ordinance, 2021 has been promulgated on February 12, 2021 after approval by the President of Pakistan.

As per the ordinance the levy of super tax on banks shall continue beyond Tax Year 2021. Through the ordinance the levy shall apply in tax year 2021 and onwards.

With this amendment the banks shall pay the super tax at four percent in subsequent tax years. For the banking companies the tax year 2022 has commenced from January 01, 2021.

The one-time super tax was imposed by inserting Section 4B of Income Tax Ordinance, 2001 through Finance Act, 2015.

The Income Tax Ordinance, 2001 explained the super tax as:

“4B. Super tax for rehabilitation of temporarily displaced persons.― (1) A super tax shall be imposed for rehabilitation of temporarily displaced persons, for tax years 2015 and onwards, at the rates specified in Division IIA of Part I of the First Schedule, on income of every person specified in the said Division.

(2) For the purposes of this section, “income” shall be the sum of the following:—

(i) profit on debt, dividend, capital gains, brokerage and commission;

(ii) taxable income (other than brought forward depreciation and brought forward business losses) under section (9) of this Ordinance, if not included in clause (i);

(iii) imputable income as defined in clause (28A) of section 2 excluding amounts specified in clause (i); and

(iv) income computed, other than brought forward depreciation, brought forward amortization and brought forward business lossess under Fourth, Fifth, Seventh and Eighth Schedules.

(3) The super tax payable under sub-section (1) shall be paid, collected and deposited on the date and in the manner as specified in sub-section (1) of section 137 and all provisions of Chapter X of the Ordinance shall apply.

(4) Where the super tax is not paid by a person liable to pay it, the Commissioner shall by an order in writing, determine the super tax payable, and shall serve upon the person, a notice of demand specifying the super tax payable and within the time specified under section 137 of the Ordinance.

(5) Where the super tax is not paid by a person liable to pay it, the Commissioner shall recover the super tax payable under subsection (1) and the provisions of Part IV,X, XI and XII of Chapter X and Part I of Chapter XI of the Ordinance shall, so far as may be, apply to the collection of super tax as these apply to the collection of tax under the Ordinance.

(6) The Board may, by notification in the official Gazette, make rules for carrying out the purposes of this section.”

In tax year 2018 the rate of super tax was four percent for banking companies on percentage of income and three percent on person other than a banking company, having income equal to or exceeding Rs500 million.

In tax year 2020 the tax rate at 4 percent was maintained for banking companies. However, in other cases it was abolished.

With the new amendment, the banking companies shall continue to pay the super tax with not time frame.

16/02/2021

FBR is Investigating Alleged Multi-Billion Rupee Scam by MG

As per a recent media report, the Federal Board of Revenue (FBR) has launched an investigation against a new entrant in the automotive industry of Pakistan. The automaker allegedly under-invoiced the customs value of one of its highly-desirable and most expensive vehicles in the lineup. The report states that the automaker is MG, and the vehicle is HS SUV.

The report adds that FBR had managed to procure the “document,” which contains the details about the import of the vehicle. The document is reportedly under the observation of the authorities. However, it has been revealed that the company had, imported 400 Completely Builtup Units (CBUs) from China, most of which were MG HS SUVs, when FBR took notice of the issue.

The report further claims that the automaker had declared the customs value of the vehicle as $11,632, which is “massively understated” since the vehicle is being sold in other countries for over $27,000. The said “document,” which contains the details of the alleged scam, has also been shared with the relevant Ministries for a detailed investigation.

The under-invoicing scam has potentially caused billions of rupees worth of losses to the national exchequer. Having imported over 400 CBU units, the automaker has allegedly evaded over Rs 1.1 billion worth of duty and taxes to date.

The news about the said development came yesterday and understandably became an instant matter of worry for the automaker. Javed Afridi – the key-stake holder of MG Pakistan – has been fairly active on social media as of late. On the same day, Afridi took to social media to make the following statement:

For decades, Pakistani automobile consumers have been exploited by cartels that cornered them with low quality, boring models at exorbitant prices. Plus, buyers had to pay billions of rupees to get delivery of the very vehicles the price of which they had already paid. As new entrants bring in exciting new models at far lower prices, instead of competition, we expect maligning campaigns and baseless rumors. While we know that competition is an unfamiliar phenomenon in Pakistan’s automobile industry, we invite everyone to join in a fair competition to serve Pakistani consumers with a bigger and better variety of vehicles at lower prices.

The reports of the scam have sparked the interest of numerous analysts and media outlets, as they all contemplate in wonder as to what might be the future of MG after this development going forward.

13/02/2021

ISLAMABAD: The Federal Board of Revenue (FBR) has taken a major policy decision of not reverting back to sales tax zero-rating regime for five export-oriented sectors including textile, leather, surgical, carpets, and sports goods, in the upcoming 2021-22.

Sources told Business Recorder here on Thursday that the zero-rating regime would not be restored due to speedy payment of refund mechanism under the “FASTER” system of the Federal Board of Revenue (FBR).

There is a significant progress on account of payment of sales tax refunds under the "FASTER" system, and there is no justification of the restoration of the sales tax zero-rating regime.

"We cannot say that all refunds are paid without delay under the FASTER system, but most of the refunds are now being cleared. A presentation of the FBR to the Finance Ministry, Ministry of Commerce and other departments at the FBR here on Thursday shows satisfactory performance of the FBR regarding payment of sales tax refunds. The FBR has informed the meeting that the system is improving day by day and there is no reason for reverting back to the old system," top officials added.

According to the sources, the government has therefore taken the decision to retain the existing sales tax regime on five export sectors textile, leather, carpets, surgical, and sports goods.

The Ministry of Industries and Production and the Commerce Ministry had proposed the restoration of the zero-rating regime for the five leading export sectors.

The FBR has already opposed a proposal of the textile sector for the restoration of zero-rating regime or applicability of a lower rate of sales tax on five export-oriented sectors.

Exporters have approached the prime minister and different parliamentary committees, underscoring the need for restoring the sales tax zero-rating regime in the budget 2021-22.

The alternate proposal of the industry was to reduce the sales tax rate from 17 percent to a lower percentage like five percent on the five export-oriented sectors. However, the FBR is against the withdrawal of the sales tax regime.

According to sources, the FBR can only propose to the policy makers and the final decision would be taken by the government.

13/02/2021

ISLAMABAD: The Federal Board of Revenue (FBR) claimed on Friday that the tax reforms introduced by the country’s tax authority have started paying dividends.

The FBR said it had introduced multiple tax reforms in line with the vision of the Prime Minister.

The country’s premier tax collection agency said that it has gathered data from different utility agencies and other departments to have a 360-degree view of taxpayers.

FBR said its reforms focused on facilitating taxpayers, reducing human interaction, simplification of tax statutes and tax filing procedures through automation, integrity management, enforcement of tax code and policy measures to boost revenue and promote exports through an increase in business activity, speedy payment of refunds and drawbacks and better service delivery.

Read more: FBR limits whistleblowing cash reward at Rs5m

FBR claimed it exceeded its seven-month revenue target for the ongoing FY 2020-21 by collecting Rs2,570 billion against the target of Rs2,550 billion because of the reforms.

The body said that it was able to collect the amount even though it has issued 80% more refunds in comparison with the same period of the last FY.

The move has helped the business community in reducing the cost of doing business and providing working capital for investment.

To boost the tax collection the FBR has also made it an easier income tax returns form for individuals and small & medium enterprises. It has also enabled auto-calculation and phase 1 of pre-filling of some information for individual taxpayers.

On the other hand, FBR has introduced an e-Appeals module to file appeals through the system. Automation of Sales Tax refunds via FASTER has been further improved. Similarly, the processing and payment of export duty drawbacks have also been automated.

To broaden the tax base, data from the financial services sector, telcos, utility companies, provincial revenue authorities, local development authorities, provincial excise & taxation authorities, local housing authorities, Securities & Exchange Commission, NADRA, and Federal Investigation Agency is being received and integrated to provide a full 360-degree view of all taxpayers.

The country’s tax collection authority has introduced a dedicated portal (Maloomat TaxRay) for taxpayers to see what information the FBR holds about them.

Moreover, the systems used for Prosecution, Appellate, and Alternate Dispute Resolution systems have been strengthened, revitalized, and automated. Additionally, on the Customs side, the anti-smuggling and confiscation of goods portal have been enabled for data collection and analysis.

Another positive development has been seen in the number of duty drawback claims processed via Automated Export Duty Drawback payment system. Since its official launch at end-December (as of 15 January 2021), 74pc of all claims (55,790 out of 75,345) have been automated whilst 71pc of amount has been remitted.

27/01/2021

The Federal Board of Revenue (FBR) has issued a legal clarification that the ‘salaried individuals’ are not required to update their ‘Tax Profiles’.

According to an FBR clarification issued to the Lahore-based chartered accountant firm, the Salaried Individuals are not required to update their Tax Profile. However, every person applying for registration under section 181 of the Income Tax Ordinance 2001, including Salaried Individual, is required to update the Tax Profile.

The option to verify changes has been given in Tax Profile for submission of changes made in the Profile, FBR maintained.

The e-intermediaries have been enabled to update the Tax Profiles of Taxpayers. However, e-intermediary needs to be nominated by Taxpayer to update the Tax Profile, FBR added.

Through an income tax circular 8 of 2020, the FBR has already extended the last date of submitting the Taxpayer’s Profile by up to March 31,2021

According to the FBR’s circular, in the exercise of the powers conferred under Section 214A of the Income Tax Ordinance, 2001, the FBR has extended the last date of furnishing of Taxpayer’s Profile required to be submitted under Section 114A ibid up to March 31, 2021.

The FBR has also issued a user guide (profile update under Section 114A of the Income Tax Ordinance, 2001) for the taxpayers. Under the law, the taxpayer’s profile contains information relevant to income regarding bank accounts, utility connections, business premises including all manufacturing, storage, or retail outlets operated or leased by the taxpayer, types of businesses, and such other information as may be prescribed by the board.

Presently, if a person fails to furnish or update a taxpayer’s profile within the due date or period as extended by the board under Section 214A, such person shall not be included in the active taxpayers’ list for the latest tax year ending before the aforesaid due date or extended date.

The condition for submission of the “Taxpayer’s profiles” covers certain categories of taxpayers, i.e., persons applying for registration, persons deriving income chargeable to tax under the head, “income from business,” income subject to final taxation, non-profit organizations, and any trust or welfare institution.

Those registered before September 30, 2020, having business income or incomes subject to final taxation, trusts, welfare institutions, and non-profit organizations are required to file taxpayers’ profile on or before December 31, 2020. The “taxpayer’s profile” shall be filed electronically in the prescribed format as provided on the IRIS Web Portal.

However, upon filing or updating the profile, such persons shall be allowed to be placed on the active taxpayers’ list upon payment of the surcharge, which is proposed to be Rs. 20,000 in the case of a company, Rs. 10,000 in the case of an association of persons, and Rs. 1,000 in the case of an individual.

The FBR said that the persons who obtain their registration after September 30, 2020, are proposed to furnish such profile within 90 days of registration. In case of any change in particulars of information, such persons shall update their profile within 90 days of the change in particulars.