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Manpower recruitment and outsourcing services

CA Finalist, ACCA FinalistReviewed by Chartered Advisory Team of Chartered Accountants
Sales tax guide: Sales tax on manpower and outsourcing services
Quick answer: Manpower supply, recruitment and outsourcing services are taxable services under provincial sales tax, generally at the standard rate, administered by the relevant authority, with Islamabad under FBR. For manpower supply the taxable value is often the full amount charged, including the salaries of the staff supplied, whereas a pure recruitment fee may be taxed on the fee alone — a distinction to confirm with the authority.

Manpower supply, staffing, recruitment and business-process outsourcing are taxable services, and the sector shares security's defining question: is the tax on the whole charge, including the salaries passed through to the client, or only on the agency's fee? The answer shapes the tax on every contract. This guide sets out the treatment and the crucial value distinction.

A taxable provincial service

Manpower supply, recruitment and outsourcing services are taxable services under provincial sales tax, generally at the province's standard rate, administered by the relevant authority — SRB, PRA, KPRA or BRA — with Islamabad under FBR. A manpower or outsourcing firm charges provincial sales tax on its charges and files with the provincial authority. Whether the firm supplies temporary staff, runs an outsourced function, or places permanent hires, its services fall within the provincial net.

The taxable value question

The pivotal issue is the taxable value. Where an agency supplies staff and charges the client for them, the taxable value is often the full amount chargedincluding the salaries of the supplied staff, not merely the agency's margin. So on a manpower-supply contract, the tax base can be the gross charge, even though much of it is passed through to the workers as wages. This is the same gross-value feature seen in security services, and it substantially affects the tax on a manpower contract: an agency that assumes sales tax applies only to its thin margin, while the large salary pass-through escapes, can badly under-declare. Because the point is significant and the rules vary, an agency should confirm the basis with its authority rather than assume.

Pure recruitment can differ

A pure recruitment service may be treated differently. Where an agency simply finds and places a candidate for a one-off fee — and the candidate is then employed directly by the client — the taxable value may be the recruitment fee alone, because there is no ongoing pass-through of salaries through the agency. This contrasts with manpower supply, where the agency supplies and continues to charge for the staff, and the gross-value question bites. The distinction therefore runs between placing someone (fee-based, potentially taxed on the fee) and supplying people on an ongoing basis (potentially taxed on the gross charge including wages). This resembles the commission-versus-supply distinction in agency arrangements. Which category a particular service falls into should be confirmed with the authority, as it determines the tax base.

Worked illustration. An agency in Sindh supplies a team of staff to a client on an ongoing basis and charges a monthly amount covering their salaries plus a margin. It accounts for provincial sales tax through SRB on the full monthly charge, confirming that the gross-value basis applies. Separately, it places a permanent hire directly with another client for a one-off recruitment fee, and treats that fee as the taxable value, there being no ongoing salary pass-through.

Common mistakes

  • Charging sales tax only on the agency\'s margin when the gross-value basis applies to manpower supply.
  • Treating manpower or outsourcing services as outside the provincial net.
  • Confusing ongoing manpower supply with one-off recruitment for the taxable value.
  • Overlooking withholding by clients on manpower-service payments.
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Where it fits

Manpower shares its gross-value feature with security services and its supply-versus-fee distinction with agency and commission arrangements. For province detail, see the Sindh (SRB) and Punjab (PRA) overviews. Manpower supply is often taxed on the gross charge; pure recruitment on the fee.

An evidence-led way to apply this guidance

The useful question in Manpower recruitment and outsourcing services is not simply whether a rule exists. For Manpower recruitment and outsourcing services, the file must prove the facts that make the rule apply. Start the Manpower recruitment and outsourcing services working by writing down classification, place of supply, registration status and the exact invoice base. Then tie each Manpower recruitment and outsourcing services conclusion to contract, tax invoice, customer location, payment trail and the return working. That article-specific exercise separates a defensible Manpower recruitment and outsourcing services position from one built around a label, a memory or a copied rate.

The legal starting point for Manpower recruitment and outsourcing services is the Punjab Sales Tax on Services Act 2012, Sindh Sales Tax on Services Act 2011, Khyber Pakhtunkhwa Finance Act 2013 or Balochistan Sales Tax on Services Act 2015, as applicable, plus current rules and notifications. The operational check for Manpower recruitment and outsourcing services belongs with the competent provincial revenue authority. Read the instrument, current guidance and actual transaction together for Manpower recruitment and outsourcing services: guidance explains administration, but it does not rewrite the law or repair missing evidence.

Rate discipline. The 15% used below is an explicit case assumption for Manpower recruitment and outsourcing services, not a substitute for checking the rate that applies to the actual period, supply, entity or election. For Manpower recruitment and outsourcing services, replace that assumption with the confirmed current rate before the working is used in a return or invoice.

An evidence-led way to apply this guidanceDecision file for Manpower recruitment and outsourcing services
CheckpointEvidence to place on fileReviewer question
Legal triggerthe Punjab Sales Tax on Services Act 2012, Sindh Sales Tax on Services Act 2011, Khyber Pakhtunkhwa Finance Act 2013 or Balochistan Sales Tax on Services Act 2015, as applicable, plus current rules and notificationsWhich fact activates the Manpower recruitment and outsourcing services rule, and where is that fact evidenced?
Period and cut-offDated contract, invoice, return period and acknowledgementDoes the Manpower recruitment and outsourcing services amount belong in this period rather than the one before or after it?
Classificationcontract, tax invoice, customer location, payment trail and the return workingWould an independent reviewer reach the same Manpower recruitment and outsourcing services classification from the documents alone?
Rate or treatmentCurrent authority publication saved with the workingWas the Manpower recruitment and outsourcing services source effective on the transaction date?
Submission trailFinal computation, payment proof and portal receiptCan the Manpower recruitment and outsourcing services filed figure be rebuilt without asking the preparer?

Two worked case files

Worked example 1 — build the taxable invoice base. For a file concerning Manpower recruitment and outsourcing services, assume the records show Rs 950,000 as the gross contract and invoice value, Rs 130,000 as the separately documented out-of-scope component, and Rs 30,000 as the credit note or price adjustment. The taxable value carried to the rate working for Manpower recruitment and outsourcing services is therefore Rs 790,000:

Two worked case filesWorked base for Manpower recruitment and outsourcing services
LineAmountFile reference
gross contract and invoice valueRs 950,000Primary control schedule
Less: separately documented out-of-scope component(Rs 130,000)Supporting document index
Less: credit note or price adjustment(Rs 30,000)Reviewer-approved adjustment
taxable value carried to the rate workingRs 790,000Signed computation

WORKING 1 Rs 790,000 x 15% = Rs 118,500; Rs 790,000 + Rs 118,500 = Rs 908,500

The arithmetic is the easy part of Manpower recruitment and outsourcing services. The Manpower recruitment and outsourcing services judgement sits in classification of the supply, place of supply, tax point and documentary support for each exclusion, including why Rs 130,000 and Rs 30,000 were removed. If any Manpower recruitment and outsourcing services answer is weak, keep the amount in the exception list rather than forcing it into a filing, resolution or account.

Worked example 2 — reconcile the return to customer balances. For Manpower recruitment and outsourcing services, assume Rs 1,425,000 as the customer-ledger control total, Rs 150,000 as the receipts matched to tax invoices, and Rs 45,000 as the valid credit notes and timing differences. The open amount supported by the return file for Manpower recruitment and outsourcing services is Rs 1,230,000.

WORKING 2 Rs 1,425,000 - Rs 150,000 - Rs 45,000 = Rs 1,230,000

For Manpower recruitment and outsourcing services, place the Rs 1,425,000 customer-ledger control total, the Rs 150,000 support for the receipts matched to tax invoices, and the Rs 45,000 schedule for the valid credit notes and timing differences beside the final Rs 1,230,000 balance. A Manpower recruitment and outsourcing services reviewer should be able to move from source evidence to control total, from control total to decision, and from decision to the submitted figure without a hidden spreadsheet or oral explanation.

The final quality-control questions

  • Has the file for Manpower recruitment and outsourcing services identified the controlling law and the version effective for the relevant date?
  • Are the Manpower recruitment and outsourcing services assumptions visibly labelled and separated from enacted rates, thresholds and deadlines?
  • Do the Rs 790,000 and Rs 1,230,000 results reconcile to source evidence and the general ledger?
  • Is every Manpower recruitment and outsourcing services exception assigned to a person and date rather than buried in a note?
  • Has the client or responsible officer approved the Manpower recruitment and outsourcing services facts before submission?

This is the standard that makes Manpower recruitment and outsourcing services useful in practice: the conclusion is stated, the law is named, the numbers can be recomputed, and the evidence survives after the person who prepared the file has moved on.

Confirm before you rely on this. Manpower-service rates and the taxable value are set by provincial law and the relevant authorities and change regularly. Confirm the current position from SRB, PRA, KPRA, BRA or FBR, or a qualified tax adviser.

Sources

This guide is written against the official and clearly labelled professional references below. Rates, thresholds and portal procedures change between reviews, so open the primary source before relying on a figure.

Questions people also ask

Are manpower and outsourcing services subject to sales tax?

Yes. Manpower supply, recruitment and outsourcing services are taxable services under provincial sales tax, generally at the standard provincial rate, administered by the relevant authority, with Islamabad under FBR. A manpower or outsourcing firm charges provincial sales tax on its charges and files with the provincial authority.

Is sales tax charged on the staff salaries passed through?

For manpower supply, often yes. Where an agency supplies staff and charges the client for them, the taxable value is often the full amount charged — including the salaries of the supplied staff, not just the agency's margin. So the tax base can be the gross charge. This is a significant point that agencies should confirm, because it substantially affects the tax on a manpower contract.

Is pure recruitment taxed differently from manpower supply?

It can be. A pure recruitment service — finding and placing a candidate for a one-off fee, where the candidate is then employed directly by the client — may be taxed on the recruitment fee alone, since there is no ongoing pass-through of salaries. Manpower supply, where the agency supplies and continues to charge for staff, is where the gross-value question arises. The distinction should be confirmed with the authority.

Scope note: General educational information for Pakistan, not a legal opinion or a substitute for advice based on your documents. Law, notifications, portal procedures and individual facts can change the result.
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