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Sales tax on services versus goods

CA Finalist, ACCA FinalistReviewed by Chartered Advisory Team of Chartered Accountants
Sales tax guide: Sales tax on services versus goods in Pakistan
Quick answer: Sales tax on goods is federal, administered by FBR, while sales tax on services is provincial, administered by each province's revenue authority (PRA, SRB, KPRA, BRA). A business supplying both registers with FBR for goods and the relevant provincial authority for services, and files separately with each.

One of the first things that confuses a new business in Pakistan is discovering that "sales tax" is not one tax administered by one authority. Goods and services are taxed by different governments under different laws, and a business that supplies both has to deal with both systems at once. This split — federal for goods, provincial for services — is a consequence of the constitutional division of taxing powers, and getting it right at the outset avoids registering in the wrong place and filing the wrong returns.

The federal-provincial split

The dividing line is the nature of the supply:

  • Goods are within federal jurisdiction. Sales tax on goods is charged under the Sales Tax Act 1990 and administered by the Federal Board of Revenue.
  • Services are within provincial jurisdiction. Each province charges sales tax on services under its own law, through its own revenue authority.

The four provincial authorities are the Punjab Revenue Authority (PRA), the Sindh Revenue Board (SRB), the Khyber Pakhtunkhwa Revenue Authority (KPRA) and the Balochistan Revenue Authority (BRA), with the Islamabad Capital Territory operating its own arrangement for services. Each has its own registration, its own return, its own rates and its own rules. A service business does not register "for sales tax" in the abstract — it registers with the specific authority for the province where it operates.

Why this matters practically

The split has three immediate consequences for a business:

  1. Where you register. Goods → FBR; services → the relevant provincial authority. Registering with the wrong one does not discharge the obligation to the right one.
  2. How many returns you file. A goods-only business files with FBR. A services-only business files with one provincial authority. A business doing both files with each — and a services business operating in several provinces may file with several provincial authorities.
  3. How input tax works. Input tax adjustment across the federal and provincial systems is subject to arrangements between the authorities, and the ability to offset service-sector input tax against goods output tax, or vice versa, is not automatic. This is a technical area covered separately under input tax adjustment and apportionment.
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Classifying the supply

Because everything follows from whether a supply is a good or a service, classification is the decision that matters. Most supplies are obvious — a manufacturer sells goods, a consultant sells services — but the edges cause disputes. Software, digital deliverables, works contracts that combine materials and labour, restaurant supplies that mix food and service, and franchising all sit near the boundary. Where a single arrangement contains both a goods element and a services element, it may need to be split, with the goods portion reported federally and the services portion provincially. When in doubt, check the position with the specific authority, because the provinces and FBR do not always classify a borderline supply the same way.

Worked example. A company sells air conditioners (goods) and also provides annual maintenance contracts (a service). It registers with FBR for the equipment sales and files federal sales tax returns for them; it registers with the provincial authority where it provides maintenance and files provincial returns for the service revenue. One customer invoice covering both a unit and a maintenance plan may need the two elements shown separately so each lands in the right return.

Mixed supplies and cross-province services

Two situations reliably cause difficulty. The first is the mixed supply above, where a bundled price has to be unbundled for tax. The second is the cross-province service — a firm based in Punjab serving a client in Sindh, for example. Provincial sales tax on services generally attaches where the service is rendered or the taxable activity occurs, but the provinces apply their own sourcing rules and more than one may assert a claim on the same service. This overlap is a live area of dispute, and a business with cross-province service revenue should confirm each relevant authority's position rather than assume a single province taxes the service.

Registering and reconciling

The practical route is: classify your supplies, then register where each requires — see sales tax registration for the federal process and provincial sales tax on services for the provincial side. Keep the federal and provincial returns reconciled to one revenue figure so the totals tie to your income tax turnover, and make sure your invoices meet sales tax invoice requirements for whichever system they belong to. Remember too that the sales tax registration number differs from the income tax number — see STRN versus NTN — so a business in both systems carries multiple registrations.

An evidence-led way to apply this guidance

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

The legal starting point for Sales tax on services versus goods 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 Sales tax on services versus goods belongs with the competent provincial revenue authority. Read the instrument, current guidance and actual transaction together for Sales tax on services versus goods: 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 Sales tax on services versus goods, not a substitute for checking the rate that applies to the actual period, supply, entity or election. For Sales tax on services versus goods, 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 Sales tax on services versus goods
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 Sales tax on services versus goods rule, and where is that fact evidenced?
Period and cut-offDated contract, invoice, return period and acknowledgementDoes the Sales tax on services versus goods 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 Sales tax on services versus goods classification from the documents alone?
Rate or treatmentCurrent authority publication saved with the workingWas the Sales tax on services versus goods source effective on the transaction date?
Submission trailFinal computation, payment proof and portal receiptCan the Sales tax on services versus goods filed figure be rebuilt without asking the preparer?

Two worked case files

Worked example 1 — build the taxable invoice base. For a file concerning Sales tax on services versus goods, assume the records show Rs 900,000 as the gross contract and invoice value, Rs 100,000 as the separately documented out-of-scope component, and Rs 25,000 as the credit note or price adjustment. The taxable value carried to the rate working for Sales tax on services versus goods is therefore Rs 775,000:

Two worked case filesWorked base for Sales tax on services versus goods
LineAmountFile reference
gross contract and invoice valueRs 900,000Primary control schedule
Less: separately documented out-of-scope component(Rs 100,000)Supporting document index
Less: credit note or price adjustment(Rs 25,000)Reviewer-approved adjustment
taxable value carried to the rate workingRs 775,000Signed computation

WORKING 1 Rs 775,000 x 15% = Rs 116,300; Rs 775,000 + Rs 116,300 = Rs 891,300

The arithmetic is the easy part of Sales tax on services versus goods. The Sales tax on services versus goods judgement sits in classification of the supply, place of supply, tax point and documentary support for each exclusion, including why Rs 100,000 and Rs 25,000 were removed. If any Sales tax on services versus goods 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 Sales tax on services versus goods, assume Rs 1,275,000 as the customer-ledger control total, Rs 180,000 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 Sales tax on services versus goods is Rs 1,050,000.

WORKING 2 Rs 1,275,000 - Rs 180,000 - Rs 45,000 = Rs 1,050,000

For Sales tax on services versus goods, place the Rs 1,275,000 customer-ledger control total, the Rs 180,000 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 1,050,000 balance. A Sales tax on services versus goods 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 Sales tax on services versus goods identified the controlling law and the version effective for the relevant date?
  • Are the Sales tax on services versus goods assumptions visibly labelled and separated from enacted rates, thresholds and deadlines?
  • Do the Rs 775,000 and Rs 1,050,000 results reconcile to source evidence and the general ledger?
  • Is every Sales tax on services versus goods exception assigned to a person and date rather than buried in a note?
  • Has the client or responsible officer approved the Sales tax on services versus goods facts before submission?

This is the standard that makes Sales tax on services versus goods 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. Rates, classifications and sourcing rules differ between FBR and each provincial authority and change over time. Confirm the current position with the relevant authority or take advice before registering or filing.

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

Do I register for sales tax with FBR or my provincial authority?

It depends on what you supply. Goods are federal, so goods suppliers register with FBR. Services are provincial, so a service provider registers with the revenue authority of the province where the service is rendered — PRA in Punjab, SRB in Sindh, KPRA in Khyber Pakhtunkhwa, BRA in Balochistan. A business doing both registers in both systems.

My business supplies both goods and services. Do I file two returns?

Yes. Because the two are administered by different authorities, you file a federal sales tax return for the goods with FBR and a provincial return for the services with the relevant provincial authority. The two returns should reconcile to the same underlying revenue, and keeping the classification clean at invoicing is what makes that reconciliation possible.

Which province taxes a service if my client is in another province?

Provincial sales tax on services generally follows where the service is rendered or the taxable activity takes place, but the provinces apply their own rules and there can be overlap where a service touches more than one province. This is one of the genuinely contested areas of Pakistani indirect tax, so a cross-province service arrangement is worth checking against each authority's position rather than assuming a single answer.

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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