A Decoding of the Place of Provision for Advertisement Services

If you’re an advertiser, broadcaster, or anyone involved in the intricate world of Pakistani media, a recent notification on the place of provision of services relating to advertisement might have raised your eyebrows. Let’s unravel this dense legal document and shed light on where your advertising services fall under the tax spotlight.

The Rules, Simplified:

The notification SRO494(I)2023 lays out specific locations within the Islamabad Capital Territory (ICT) or beyond, considered the “place of provision” for various advertising methods. This location determines which tax regime applies to your service. Here’s a breakdown of the key points:


  • Satellite broadcasts: The location of the station beaming the ad (uplinking station) governs the tax.
  • Terrestrial signals: Taxable at the location of the first broadcast station.
  • TV channels with landing rights: The place of provision shifts to the person holding PEMRA’s landing rights license.
  • IPTV: Taxable at the location of the licensing zone specified in the PEMRA license.
  • Cable TV and other distribution services: The area of coverage assigned to the respective license holder for the chosen service determines the tax location.

Beyond Television:

  • Closed-circuit TV: Taxed at the location of the closed-circuit TV system.
  • Websites and webpages: The location of the person owning or managing the website governs the tax.
  • Radio broadcasts:
    • Satellite: Taxed at the location of the station uplinking the ad.
    • Terrestrial: Taxable at the location of the first broadcast station.
  • Still media (billboards, etc.): Taxed at the location of the media itself.
  • Cinema and aerial advertising: Taxable at the location of the cinema or the jurisdiction where the aerial ad takes place.

Special Cases:

  • Ads booked in ICT for channels outside Pakistan: Considered provided in ICT, regardless of landing rights.
  • Ads booked in ICT for non-resident websites: Tax location shifts to the person booking the ad.

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