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Approved Gratuity Funds (AGFs) in Pakistan: Structure, Tax Benefits, and Compliance

Approved Gratuity Funds (AGFs) offer tax-free gratuity payments and legal protection for employees. Here's how companies can qualify and apply in Pakistan.

Gratuity is a key part of long-term employee compensation in Pakistan. For organizations aiming to formalize their gratuity arrangements and ensure both tax efficiency and regulatory compliance, establishing an Approved Gratuity Fund (AGF) is a strategic move.

Under the Income Tax Ordinance, 2001, AGFs provide a recognized legal and financial framework to manage gratuity payments — offering not just employee security but also significant tax exemptions on gratuity amounts paid under such schemes.


️ What Is an Approved Gratuity Fund (AGF)?

An Approved Gratuity Fund is a gratuity payment scheme that has been formally approved by the Commissioner of Income Tax under Pakistan’s tax law. It must fulfill strict conditions to ensure the trustworthiness, purpose-specific use, and local benefit of the gratuity payments.

Once approved, the gratuity payments made under this fund become fully exempt from tax for the employees, subject to compliance with the governing rules.


✅ Conditions for AGF Approval

For a gratuity scheme to be recognized as an AGF, it must meet the following legal and operational criteria:

1. Irrevocable Trust Structure

  • The fund must be created under an irrevocable trust, meaning the assets cannot be taken back or redirected for any other use.
  • It must be directly connected to a trade or undertaking in Pakistan, ensuring local economic relevance.

2. Minimum Employee Coverage (Pakistan-Based)

  • At least 90% of the employees covered by the AGF must be based in Pakistan.
  • This ensures that the primary beneficiaries are contributing to the local workforce and economy.

3. Exclusive Purpose – Gratuity Only

The AGF must serve only one purpose: providing gratuity payments to employees upon:

  • Retirement at or after a certain age
  • Medical incapacitation before retirement
  • Termination after completing minimum years of service
  • Death, with payments going to legal heirs or dependents

4. Employer Must Contribute

  • The employer must contribute financially to the AGF, proving its genuine commitment to long-term employee benefits.
  • Without employer contribution, the fund does not qualify.

5. Payments Must Be Made Within Pakistan

  • All benefits and payouts from the AGF must be paid inside Pakistan, not abroad.
  • This maintains the local impact and jurisdictional integrity of the fund.

How to Apply for AGF Approval

The trustees of the proposed AGF are responsible for submitting an application to the Commissioner of Income Tax. The following documents are required for consideration:

Required Documents:

  1. Trust Deed (Certified Copy): This is the legal foundation of the AGF and must clearly state its irrevocable nature and purpose.
  2. Fund Rules (2 Copies): These rules govern how the fund operates, including eligibility criteria, contribution process, disbursement terms, and administrative powers.
  3. Audited Financial Accounts (Optional but Advised): If the fund was operating before applying for approval, submitting audited accounts for the last 3 years is recommended to showcase financial credibility.
  4. Any Additional Information (On Request): The Commissioner may ask for further documents to verify compliance and intent.

Ongoing Compliance After Approval

Approval is not a one-time exercise. Once granted, the trustees must ensure the AGF remains compliant with:

1. Income Tax Ordinance, 2001

  • All relevant clauses and changes in the law must be followed.
  • Amendments in tax law could affect fund operations and exemptions.

2. The Fund’s Own Rules and Trust Deed

  • The fund must operate strictly within its originally approved framework.
  • Any deviation or misuse could risk revocation of approval and loss of tax benefits.

Trustees are responsible for keeping records, managing distributions transparently, and filing any necessary reports or declarations as required.


Frequently Asked Questions (FAQs)

What is an Approved Gratuity Fund (AGF)?

An Approved Gratuity Fund is a gratuity scheme that has been officially approved by the Commissioner of Income Tax. It must be established under an irrevocable trust and meet strict legal and regulatory conditions to provide tax-free gratuity benefits to employees.


Who can set up an Approved Gratuity Fund?

Any employer in Pakistan—whether a company, partnership, or organization—can establish an AGF, provided it is linked to a legitimate trade or undertaking within the country and adheres to all conditions set in the Income Tax Ordinance, 2001.


Is gratuity paid from an AGF exempt from tax?

Yes. Gratuity paid to employees from an Approved Gratuity Fund is fully exempt from income tax, subject to compliance with AGF rules and approval by the tax authorities.


Who applies for AGF approval?

The trustees of the gratuity fund are responsible for applying to the Commissioner of Income Tax, along with submitting required documentation like the trust deed, fund rules, and (if available) audited financials.


Can an AGF lose its approved status?

Yes. If the fund violates any legal conditions or deviates from its original rules, the Commissioner may revoke its approval. This could lead to loss of tax exemptions and potential penalties.


Is AGF approval permanent?

Approval remains valid as long as the fund remains compliant with the Income Tax Ordinance and the fund’s own governing rules. Trustees must ensure ongoing adherence to avoid regulatory issues.


Final Thoughts

An Approved Gratuity Fund (AGF) is not just a tax-saving tool — it’s a commitment to long-term employee welfare. Companies that set up AGFs demonstrate professionalism, legal compliance, and financial discipline.

For employees, an AGF-backed gratuity ensures full tax exemption, predictable payment, and peace of mind during retirement, resignation, or family transitions.

If your company is planning to register a gratuity fund or needs assistance preparing the application documents, contact TaxationPk for expert help.

Mah Noor
Mah Noor

An aspiring Chartered Accountant with a growing footprint in Pakistan’s tax education and digital finance content landscape. Currently, I work as the Editor-in-Chief at TaxationPk, where I lead content strategy, quality control, and editorial planning for tax-related blogs, news articles, and social media outreach.

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4 Comments

  1. Dear Concern
    I have applied for the adoption of average tax rate on my gratuity received to the commissioner office, but they told me that the gratuity will taxed at normal rate for the preceding year.
    Kindly advice as per law & oblige

  2. If employee resigns from his job and receive gratuity amount from approved gratuity fund then this amount will be exempt or taxable and on what rate?

  3. Thanks for breakingAGF Blog Comment Creation down the structure and tax benefits of AGFs so clearly. One aspect I’d love to see explored further is how companies handle compliance over time—especially with changing tax regulations. Do most organizations appoint dedicated trustees, or is that typically outsourced?

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