The sales tax active list: a different list, a different risk
Pakistan runs two active taxpayer lists and they are not interchangeable. Businesses that know the income tax one well are frequently unaware that the sales tax list exists, and that gap shows up as disallowed input tax.
Two lists, two purposes
| Income tax ATL | Sales tax active list | |
|---|---|---|
| What it records | That an income tax return was filed for a tax year | Sales tax registration status |
| Why you check your own | Withholding rates on your transactions | Your standing as a registered supplier |
| Why you check someone else | To set the correct withholding rate on a payment | To confirm an input tax claim will hold |
| Consequence of the other party being inactive | You deduct at the higher rate | Your input claim against them is at risk |
A business can be diligently filing monthly sales tax returns while being treated as a non-filer for income tax withholding, or the reverse. Check both, for different reasons — see income tax ATL status.
Why supplier status decides your claim
The practical consequence is that supplier verification is a purchasing control rather than a compliance afterthought. On a business claiming Rs 20,000,000 of input tax a year, a single significant supplier turning out to have been inactive can produce a seven-figure adjustment plus consequences.
Two different lists, under two different statutes, are involved here and they are routinely conflated. The income tax Active Taxpayer List follows from filing a return under section 114 of the Income Tax Ordinance 2001, with restoration after late filing governed by section 182A. The sales tax active-taxpayer position is a separate register maintained under the Sales Tax Act 1990, and it is that one which decides whether your input tax claim under section 7 survives — because section 8 disallows input attributable to a supplier who was not active when the supply was made.
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Suspension, blacklisting and what each does to your claims
| Supplier status | Usual trigger | Your input tax on their supplies | What to do |
|---|---|---|---|
| Active | Returns filed, particulars verified | Admissible, subject to the other tests | Nothing |
| Inactive | Return not filed for a period | At risk for supplies made while inactive | Hold payment until restored, or switch |
| Suspended | Unverified premises, annexure mismatch, non-response | Disallowed for the suspension period | Stop claiming immediately; supplier must resolve |
| Blacklisted | Fake or flying invoices established | Disallowed, and prior claims reopened | Cease trading; expect your own claims examined |
The last row is the one that reaches backwards. Blacklisting is not only forward-looking — claims already allowed against that supplier can be reopened, so a buyer who traded with them in good faith for two years faces an assessment covering all of it. That is the case for checking monthly rather than at onboarding: it limits the exposure to one period instead of the whole relationship.
- Use the official verification facility, not the number printed on the invoice.
- Confirm the particulars match — the registered name and the entity you are actually dealing with should be the same. A number that belongs to a different business is a red flag, not a typo.
- Check at the time of the transaction, because that is the moment the status has to hold.
- Save a dated result with the purchase voucher. This is what supports the claim in a subsequent review.
- Re-verify recurring suppliers periodically. A supplier active at onboarding may not be active a year later, and monthly purchases against a lapsed registration accumulate quietly.
Suspension and blacklisting
Registrations can be suspended or blacklisted where the authority has concerns about a registered person. For a customer of that supplier, the effects are practical:
- Input tax claimed against their invoices comes under scrutiny, including for periods before the action.
- Your own claims may be examined more closely if a material proportion of your inputs came from an affected supplier.
- Contemporaneous verification is your protection. A dated check showing the supplier was active when you transacted is far stronger than a retrospective assertion.
If a regular supplier is suspended, review your position for prior periods before the next return rather than waiting for a query — sales tax audit preparation.
Keeping your own status clean
Your customers are running the same check on you, and increasingly corporate buyers require active status as a condition of payment. What keeps you on the list:
- File every monthly return, including nil returns. The obligation attaches to the registration, not to activity — filing the return.
- Keep registration particulars current — premises, bank accounts, activity, contact details.
- Respond to authority correspondence promptly. Unanswered queries are a common route to suspension.
- Maintain the records that support your filed returns.
Checking both lists, for different reasons
A business dealing with another business should be running two separate checks on the same counterparty, and confusing them leaves one exposure open:
| Check | When | What it protects |
|---|---|---|
| Income tax ATL status of the payee | Before releasing any payment subject to withholding | That you deducted at the correct rate; under-deduction exposure sits with you |
| Sales tax active status of the supplier | Before claiming input tax on their invoice | That your input claim will hold |
The same supplier can pass one check and fail the other, which is why a single verification at onboarding is not enough. Where you both buy from and pay a counterparty, both checks belong in the payment run — dated, saved with the voucher, and repeated periodically for recurring relationships. See filer versus non-filer rates.
Building it into procurement
The businesses that never have this problem treat verification as part of supplier onboarding rather than as a tax task:
- Require the registration number at onboarding and verify it before the first purchase order.
- Record the verification date in the supplier master file.
- Re-verify on a fixed cycle for recurring suppliers, and always before a large purchase.
- Make active status a condition in the supply terms.
- Retain the dated check with each payment voucher, alongside the invoice.
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.
- Sales Tax Basics (FBR)
- Register for Sales Tax (FBR)
- Sales Tax Act 1990, amended through 30 June 2026 (FBR)
- Active Taxpayer List — Income Tax (FBR)
Questions people also ask
Is this the same as the filer status list?
No. The income tax Active Taxpayer List records who filed an income tax return for a tax year and drives withholding rates. The sales tax active list concerns sales tax registration status. A business can be active on one and not the other, and the two are checked for entirely different purposes.
My supplier was active when I bought but has since been suspended. Is my claim affected?
What matters is their status at the time of supply, not today. A claim against a supplier who was properly registered and active when the supply was made is not retrospectively invalidated by a later suspension. This is exactly why the verification has to be dated and retained — a check performed now cannot establish a position from two years ago.
What does suspension or blacklisting of a supplier mean for me?
It puts input tax claimed against their invoices at risk, and it can bring your own claims under closer examination. If a supplier you use regularly is suspended, review what you have claimed against them, retain whatever contemporaneous verification you have, and take advice before the next return rather than after a query.
How do I verify a supplier properly?
Check the official verification facility using their registration number, confirm the particulars match the invoice, and save a dated result. Do not verify from the number printed on the invoice alone — a number can be transcribed wrongly, belong to a different entity, or be inactive. The check takes under a minute and it is the cheapest input tax insurance available.
Should I refuse to deal with an inactive supplier?
That is a commercial judgement, but you should not claim input tax against them, and you should price on the basis that the tax is a cost rather than a recoverable amount. Many businesses simply require active status as a condition of onboarding, which is easier to enforce at the outset than to unpick later.
Send the tax year and the transaction or filing involved, and we will tell you what is actually required.
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