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How long to keep sales tax records, and in what form

CA Finalist, ACCA FinalistReviewed by Chartered Advisory Team of Chartered Accountants
Sales tax guide: Sales tax record retention in Pakistan
Quick answer: Sales tax records must be retained for the statutory period — commonly six years — and longer where a proceeding is open. What matters as much as the duration is the form: records have to allow a reviewer to move from a return figure to a ledger total to a source document, which means transaction-level data, not summaries.

Retention rules look like an administrative footnote until an audit covers a period you can no longer evidence. At that point the question stops being what the law required and becomes what you can actually produce.

The period

Sales tax records must be retained for the statutory period prescribed under the Sales Tax Act 1990 — commonly six years — measured from the end of the tax period to which they relate.

Treat the statutory period as a floor, not a target. Where an audit, assessment, appeal or refund proceeding is open, records must be retained until it is finally concluded, which can be considerably longer. Any routine destruction schedule should be suspended entirely while anything is unresolved — and that suspension should cover the whole business, not just the period under enquiry.

What counts as a record

What counts as a record
CategoryWhat to retain
SalesTax invoices issued in serial order; credit and debit notes; the cancellation log; the sales register at invoice level
PurchasesSupplier tax invoices; the purchase register at invoice level; import documents and goods declarations
ReturnsEach monthly return, both annexures, the payment challan and the acknowledgement
ReconciliationsThe turnover reconciliation to accounting revenue; the carry-forward schedule; the apportionment working
VerificationsDated supplier status checks retained with the relevant voucher
Stock and productionInventory records; production and consumption records for a manufacturer
BankingStatements for every account for the whole period
SystemsWhere POS or digital invoicing applies, the transmission records reconciled to the returns

The obligation sits in section 24 of the Sales Tax Act 1990, which requires prescribed records to be retained for six years, and it is read with section 22, which specifies what those records are. The practical point buried in the wording is that the six years runs from the end of the tax period the record relates to — and that unresolved proceedings extend it.

What to keep, and until when

What to keep, and until when
RecordRetainWhy it is asked for
Sales tax invoices issuedSix years from the tax periodSubstantiates declared output tax
Purchase invoices receivedSix yearsThe only support for every input tax claim
Monthly returns and annexuresSix yearsReconciled against the accounts
Credit and debit notesSix yearsExplains adjustments to declared supplies
Bank statements and payment evidenceSix yearsProves the banking-channel condition
Stock and production recordsSix yearsTests input consumption against output
Anything under audit, refund claim or appealUntil resolved, then six yearsRoutine destruction can destroy live evidence

The last row overrides every other. A refund claim that has been open for three years resets nothing — the file supporting it has to survive until the claim is settled, and only then does the six-year clock begin. A destruction policy that runs on dates alone, without checking for open matters, will eventually destroy the evidence for a claim still being pursued.

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Form matters as much as duration

The test a reviewer applies is whether they can move from a figure in a filed return, to a total in your ledger, to a source document — without you present to explain it. That imposes requirements on how records are kept, not just how long:

  • Transaction-level, not summary. A monthly total cannot support an annexure built from invoices.
  • Readable and complete. A partial statement or a cropped scan invites a follow-up.
  • Audit trail preserved. Electronic records should retain the trail showing what was entered, when and by whom, rather than being exported to a flat file that could have been edited.
  • Retrievable by you. Not only by a former accountant, a superseded system or a cloud account whose subscription lapsed.
  • Organised by tax period, so a request covering one period does not require reassembling three years of files.

Practical electronic retention

  1. Keep the accounting data file itself, not just PDF reports generated from it.
  2. Export a readable archive annually — registers, returns, annexures and reconciliations — in a format you will still be able to open in six years.
  3. Back up off the primary system and test that a restore actually works. An untested backup is a hope, not a record.
  4. Retain access to superseded software or migrate historic data forward when you change systems. A system change is the single most common cause of a lost period.
  5. Download bank statements quarterly, because online access windows close.
  6. Keep supplier verification results with the vouchers rather than in a separate compliance folder.

Records at a change of accountant or system

The single most common cause of a genuinely lost period is not destruction but transition. Two events deserve a formal handover:

  • Changing accountant or bookkeeper. Obtain the accounting data file itself, not printed reports; the working papers behind each return; and confirmation of what remains outstanding. Do this before the relationship ends rather than after, when cooperation is harder to secure.
  • Changing accounting software. Either migrate historic data forward in a usable form or retain access to the old system. A migration that brings only opening balances leaves every prior period unsupported at transaction level, which is precisely the level an audit works at.

In both cases, run a verification: pick three filed returns from different years and confirm you can still trace each one from the return figure to the ledger to a source invoice. If you cannot, the handover is incomplete regardless of what was transferred — sales tax audit preparation.

The parallel obligations

Sales tax retention runs alongside other requirements with their own periods and their own scope:

  • Income tax records supporting your annual return and wealth statement — income tax retention.
  • Provincial services tax records for each authority you are registered with, on their own rules.
  • Company records under company law, including statutory registers and minute books, where you are incorporated — SECP filings.
  • Withholding records, including the computations and the certificates issued.

The simplest workable approach is a single retention policy keyed to the longest applicable period, organised by tax year, with destruction suspended whenever any proceeding is open anywhere in the business.

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

Six years from when exactly?

From the end of the tax period the records relate to, rather than from the date a document was created. That distinction matters at the margin: an invoice issued early in a period and one issued at the end of it share the same retention endpoint. Where a proceeding is open the period effectively extends, so do not destroy on a calendar rule while anything is unresolved.

Can I keep everything electronically?

Electronic retention is generally acceptable provided the records are readable, complete and retain their audit trail. What is not acceptable is a set of PDFs with no underlying data — a reviewer tracing a return figure needs to reach transaction-level records, which means the accounting data itself, not just printed reports.

My accountant holds the records. Is that sufficient?

The obligation is yours. Practices end, relationships break down and systems change, and a business that cannot produce its own records is in a poor position whoever was maintaining them. Keep your own copy of the accounting file, not just reports, and confirm you can open it independently.

What if records were lost in a fire or a system failure?

Report the position honestly and reconstruct what you can from banking records, supplier and customer confirmations, and any surviving data. Document the loss contemporaneously — a police or fire report, or an IT incident record. An honest account of a genuine loss with reconstructed alternatives is a far better position than silence or a fabricated substitute.

Do I keep records for periods when I had no activity?

Yes. Nil returns are still returns, and the absence of activity is itself something you may need to evidence. Keep the filed nil returns and the bank statements covering those periods — a dormant period with no records is harder to explain than an active one with good ones.

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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