FBR Mandates ADR for State-Owned Enterprise Tax Disputes

Islamabad, Pakistan – The Federal Board of Revenue (FBR) has implemented a new rule requiring state-owned enterprises (SOEs) to resolve their tax disputes through Alternate Dispute Resolution Committees (ADRCs).

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The FBR issued S.R.O. 1377(I)/2024 to amend the Income Tax Rules, 2002, making ADR mandatory for all SOE tax disputes, regardless of the amount involved. FBR

To initiate the ADR process, SOEs must submit a written application to the FBR in the prescribed format. The FBR will then appoint a committee of experts, including retired IRS officers, chartered accountants, and legal professionals, to review and resolve the dispute.

The committee will have 45 days, extendable by 15 days, to reach a decision. If the SOE is satisfied with the committee’s decision, they must withdraw any pending legal appeals and inform the FBR. In such cases, the committee’s decision will be binding on the tax commissioner.

Once the committee’s decision is received, the SOE must make the required tax payments. The committee members will receive a one-time remuneration of Rs. 100,000 each for their services.

The FBR’s new rule aims to streamline the dispute resolution process for SOEs, reducing the burden on the courts and promoting a more efficient tax administration system.

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