FBR Expands E-Invoicing Rules to All Taxpayer Categories

ISLAMABAD: The Federal Board of Revenue (FBR) has broadened the scope of regulations concerning e-invoicing and the consolidation of sales transactions to encompass all classifications of taxpayers, including both corporate and non-corporate entities.

Adnan Mufti, a partner at Moore Shekha Mufti, Chartered Accountants, clarified that the FBR has unveiled a revised set of guidelines for e-invoicing and sales transaction integration via Notification SRO 709(1)12025, dated April 22, 2025. This SRO 709 is rooted in Rule 150Q(2) of the Sales Tax Rules 2006. It mandates that the corporate and non-corporate sectors electronically synchronize their hardware and software with the FBR’s computerized system for e-invoice generation and transmission.

However, ambiguity persists among numerous businesses uncertain about the applicability of this new framework to Fast-Moving Consumer Goods (FMCG) companies or the entire spectrum of taxpayers.

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Mufti further clarified that the FBR initially introduced SRO 1525 on November 10, 2023, establishing Rule 150Q within the Sales Tax Rules 2006. Subsequently, SRO 28, dated January 10, 2024, confined this integration solely to the FMCG sector, effective from February 1, 2024.

More recently, SRO 69, dated January 29, 2025, presented a newly revised version of Rule 150Q. The most recent SRO 709, issued under this updated Rule 150Q, introduces two significant alterations: the taxpayer categories to which the rules apply and their effective dates. Mufti asserted that because the previous wording of Rule 150Q has been replaced, its corresponding SRO 28 has also been annulled.

Mufti emphasized that the initial integration requirements, which were previously limited to the FMCG sectors, have been revoked, and the updated procedures now extend to all categories of taxpayers (corporate and non-corporate), effective from the new deadlines in May and June 2025, depending on the specific circumstances. Addressing the apparent uncertainty, Mufti suggested that the FBR should either rescind SRO 28, dated January 10, 2024, or issue a clarifying statement to prevent potential litigation in higher courts.

He also voiced concerns over the FBR’s decision to allocate only one week for the corporate sector to implement the new framework without engaging stakeholders, deeming it impractical. The tax administration’s apparent rush is further evidenced by the fact that the Sales Tax General Orders required for the complete implementation of the scheme have yet to be issued by the FBR.

Mufti underscored the necessity of involving all relevant parties, including ICAP, PBC, FPCCI, and KTBA, to ensure the successful implementation of the new structure, resolving any technical or legal issues associated with the scheme.