The Pakistan Tax Bar Association has formally submitted 12 recommendations to Federal Board of Revenue Chairman Rashid Mahmood Langrial, urging the tax authority to urgently address structural gaps in its digital tax infrastructure before they undermine the broader objectives of the country’s ongoing taxation reforms. The association warned that weaknesses in system design, governance, and statutory alignment could undermine the objectives of ongoing digitisation reforms, identifying multiple operational issues including inconsistencies between digital processes and legal provisions, incomplete integration of Harmonized System codes, and the absence of formal mechanisms for correcting digital records. The representation marks one of the most detailed public critiques of the FBR’s IRIS system to date, coming from a professional body that deals directly with the system’s shortcomings on behalf of taxpayers and businesses on a daily basis.
Among the 12 recommendations, the association called on FBR to ensure that all laws, rules, and Statutory Regulatory Orders are fully and accurately translated into the IRIS system rather than partially implemented, and proposed a systematic audit of the digital system’s alignment with statutory provisions beginning with SRO 297(I)/2023, followed by timely corrective action. It also called for a clear roadmap for the full integration of Harmonized System codes across return annexures and invoicing modules, and proposed a review and rationalisation of the application of units of measurement in sales tax returns to ensure consistency with the Sales Tax Act 1990. The association further stressed the need to develop a formal mechanism for digital correction and rectification, including structured amendments with audit trails, which would address the current situation where taxpayers face significant difficulties in fixing errors in their digital records with no clear procedure for doing so.
On the governance side, the Pakistan Tax Bar Association proposed restoring an independent and empowered Member Information Technology position within the FBR to strengthen oversight of the digital tax infrastructure, and urged the development of jointly agreed standard operating procedures between FBR and Pakistan Revenue Automation Limited for dispute resolution and system grievances. It also called for periodic public disclosure of system performance indicators including uptime, error rates, and complaint resolution timelines to improve transparency, and recommended establishing a clear accountability framework defining the respective roles of FBR and Pakistan Revenue Automation Limited in managing the digital tax system.
To address the speed of complaint resolution, the association proposed a structured complaint handling system with direct access to FBR and Pakistan Revenue Automation Limited officials and a clear escalation mechanism, recommending that all system-related complaints be resolved within 48 to 72 hours. The proposals come at a moment when FBR’s digitization push is accelerating across multiple fronts, including mandatory e-invoicing, the IRIS 2.0 portal, and Point of Sale integration requirements for retailers. If the legal and operational gaps flagged by the Pakistan Tax Bar Association are not addressed alongside this expansion, the risk is that a system that is technically broader will remain practically unreliable, eroding taxpayer confidence precisely when the government needs compliance levels to rise to meet its revenue targets.
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