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Active Filers importing CKD kits for Electric Vehicles pay a minimal 1% tax, whereas Non-Filers pay double at 2%. • Purchasing a 1601cc to 1800cc vehicle will cost Non-Filers a 9% tax, which is three times the 3% rate given to Active Filers. • Dividends from Real Estate Investment Trusts (REITs) and general companies cost Active Filers 15% in tax, but Non-Filers lose a massive 30%. • Providing IT and IT-enabled services costs Active Taxpayers just 4% in withholding tax, while Non-Filers must pay 8%. • Profits on debt from mutual funds deriving 50% or more income from debt carry a huge 50% tax for Non-Filers, compared to 25% for Filers. • If you receive dividends from Independent Power Purchasers (IPPs), Filers pay a 7.5% tax while Non-Filers surrender 15%. • Importing pharmaceutical products carries an 8% tax for Non-Filers, which is exactly double the 4% rate applied to Active Taxpayers. • Buyers of 1301cc to 1600cc cars pay a 2% advance tax if they are Filers, but Non-Filers pay exactly triple at 6%. • Capital gains arising on the disposal of certain debt securities are taxed at 15% for Filers, but double to 30% for Non-Filers. • Buying a high-end 2501cc to 3000cc vehicle leaves Filers with a 9% tax bill, but absolutely punishes Non-Filers with a massive 27% tax rate. • Registering a 1000cc motor vehicle costs Filers just 1% in tax, while Non-Filers are penalized with a 3% tax. • Salaries under Rs. 600,000 are completely tax-free, maintaining a 0% rate regardless of your taxpayer status. • Winning a prize bond or crossword puzzle means you lose 15% to taxes as an Active Filer, but a massive 30% if you are a Non-Filer. • Importing basic goods from Part-I of the Twelfth Schedule costs Active Taxpayers just 1% in tax, while Non-Filers have to pay 2%. • Registering a 2001cc to 2500cc luxury vehicle incurs a 7% tax for Active Filers, but a staggering 21% tax for Non-Filers. • Cash withdrawals by a person whose name does not appear on the Active Taxpayers’ List are hit with an automatic 0.8% advance tax. • Winning a raffle, lottery, or sales promotion prize costs Non-Filers a whopping 40% in tax, compared to 20% for Filers. • Commercial importers bringing in Part-III items are hit with a 12% tax rate if they are Non-Filers, compared to only 6% for Active Filers. • Commercial importers of Part-II goods face a 3.5% withholding tax if they are Filers, but the rate doubles to 7% for Non-Filers. • Companies generating rental income from immovable property pay a 15% tax if they are Active Filers, but face a 30% rate as Non-Filers. • Pensions under 10 million rupees remain 100% tax-exempt for everyone, no matter what your filing status is. • The withholding tax on banking and financial institution profits is set at 20% for those on the Active Taxpayers’ List, but jumps to 40% for those off the list. • Selling rice, cotton seed, or edible oils comes with a low 1.5% tax for Filers, but a 3% tax for Non-Filers. • Payments to electronic and print media for advertising services are taxed at just 1.5% for Active Taxpayers, compared to 3% for Non-Filers. • Payments made to non-resident sportspersons incur a 15% tax if they are on the ATL, and a massive 30% if they are non-ATL. • The sale of petroleum products is taxed at 12% for Filers and exactly double that at 24% for Non-Filers. • Active Filers importing CKD kits for Electric Vehicles pay a minimal 1% tax, whereas Non-Filers pay double at 2%. • Purchasing a 1601cc to 1800cc vehicle will cost Non-Filers a 9% tax, which is three times the 3% rate given to Active Filers. • Dividends from Real Estate Investment Trusts (REITs) and general companies cost Active Filers 15% in tax, but Non-Filers lose a massive 30%. • Providing IT and IT-enabled services costs Active Taxpayers just 4% in withholding tax, while Non-Filers must pay 8%. • Profits on debt from mutual funds deriving 50% or more income from debt carry a huge 50% tax for Non-Filers, compared to 25% for Filers. • If you receive dividends from Independent Power Purchasers (IPPs), Filers pay a 7.5% tax while Non-Filers surrender 15%. • Importing pharmaceutical products carries an 8% tax for Non-Filers, which is exactly double the 4% rate applied to Active Taxpayers. • Buyers of 1301cc to 1600cc cars pay a 2% advance tax if they are Filers, but Non-Filers pay exactly triple at 6%. • Capital gains arising on the disposal of certain debt securities are taxed at 15% for Filers, but double to 30% for Non-Filers. • Buying a high-end 2501cc to 3000cc vehicle leaves Filers with a 9% tax bill, but absolutely punishes Non-Filers with a massive 27% tax rate. • Registering a 1000cc motor vehicle costs Filers just 1% in tax, while Non-Filers are penalized with a 3% tax. • Salaries under Rs. 600,000 are completely tax-free, maintaining a 0% rate regardless of your taxpayer status. • Winning a prize bond or crossword puzzle means you lose 15% to taxes as an Active Filer, but a massive 30% if you are a Non-Filer. • Importing basic goods from Part-I of the Twelfth Schedule costs Active Taxpayers just 1% in tax, while Non-Filers have to pay 2%. • Registering a 2001cc to 2500cc luxury vehicle incurs a 7% tax for Active Filers, but a staggering 21% tax for Non-Filers. • Cash withdrawals by a person whose name does not appear on the Active Taxpayers’ List are hit with an automatic 0.8% advance tax. • Winning a raffle, lottery, or sales promotion prize costs Non-Filers a whopping 40% in tax, compared to 20% for Filers. • Commercial importers bringing in Part-III items are hit with a 12% tax rate if they are Non-Filers, compared to only 6% for Active Filers. • Commercial importers of Part-II goods face a 3.5% withholding tax if they are Filers, but the rate doubles to 7% for Non-Filers. • Companies generating rental income from immovable property pay a 15% tax if they are Active Filers, but face a 30% rate as Non-Filers. • Pensions under 10 million rupees remain 100% tax-exempt for everyone, no matter what your filing status is. • The withholding tax on banking and financial institution profits is set at 20% for those on the Active Taxpayers’ List, but jumps to 40% for those off the list. • Selling rice, cotton seed, or edible oils comes with a low 1.5% tax for Filers, but a 3% tax for Non-Filers. • Payments to electronic and print media for advertising services are taxed at just 1.5% for Active Taxpayers, compared to 3% for Non-Filers. • Payments made to non-resident sportspersons incur a 15% tax if they are on the ATL, and a massive 30% if they are non-ATL. • The sale of petroleum products is taxed at 12% for Filers and exactly double that at 24% for Non-Filers. •

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Cash withdrawals by a person whose name does not appear on the Active Taxpayers’ List are hit with an automatic 0.8% advance tax. • Commercial importers bringing in Part-III items are hit with a 12% tax rate if they are Non-Filers, compared to only 6% for Active Filers. • Importing pharmaceutical products carries an 8% tax for Non-Filers, which is exactly double the 4% rate applied to Active Taxpayers. • Selling rice, cotton seed, or edible oils comes with a low 1.5% tax for Filers, but a 3% tax for Non-Filers. • Capital gains arising on the disposal of certain debt securities are taxed at 15% for Filers, but double to 30% for Non-Filers. • If you receive dividends from Independent Power Purchasers (IPPs), Filers pay a 7.5% tax while Non-Filers surrender 15%. • Payments made to non-resident sportspersons incur a 15% tax if they are on the ATL, and a massive 30% if they are non-ATL. • The sale of petroleum products is taxed at 12% for Filers and exactly double that at 24% for Non-Filers. • Importing basic goods from Part-I of the Twelfth Schedule costs Active Taxpayers just 1% in tax, while Non-Filers have to pay 2%. • Winning a raffle, lottery, or sales promotion prize costs Non-Filers a whopping 40% in tax, compared to 20% for Filers. • Registering a 1000cc motor vehicle costs Filers just 1% in tax, while Non-Filers are penalized with a 3% tax. • Salaries under Rs. 600,000 are completely tax-free, maintaining a 0% rate regardless of your taxpayer status. • Commercial importers of Part-II goods face a 3.5% withholding tax if they are Filers, but the rate doubles to 7% for Non-Filers. • Purchasing a 1601cc to 1800cc vehicle will cost Non-Filers a 9% tax, which is three times the 3% rate given to Active Filers. • Pensions under 10 million rupees remain 100% tax-exempt for everyone, no matter what your filing status is. • Providing IT and IT-enabled services costs Active Taxpayers just 4% in withholding tax, while Non-Filers must pay 8%. • Winning a prize bond or crossword puzzle means you lose 15% to taxes as an Active Filer, but a massive 30% if you are a Non-Filer. • Buying a high-end 2501cc to 3000cc vehicle leaves Filers with a 9% tax bill, but absolutely punishes Non-Filers with a massive 27% tax rate. • Dividends from Real Estate Investment Trusts (REITs) and general companies cost Active Filers 15% in tax, but Non-Filers lose a massive 30%. • Buyers of 1301cc to 1600cc cars pay a 2% advance tax if they are Filers, but Non-Filers pay exactly triple at 6%. • Profits on debt from mutual funds deriving 50% or more income from debt carry a huge 50% tax for Non-Filers, compared to 25% for Filers. • Companies generating rental income from immovable property pay a 15% tax if they are Active Filers, but face a 30% rate as Non-Filers. • Active Filers importing CKD kits for Electric Vehicles pay a minimal 1% tax, whereas Non-Filers pay double at 2%. • The withholding tax on banking and financial institution profits is set at 20% for those on the Active Taxpayers’ List, but jumps to 40% for those off the list. • Payments to electronic and print media for advertising services are taxed at just 1.5% for Active Taxpayers, compared to 3% for Non-Filers. • Registering a 2001cc to 2500cc luxury vehicle incurs a 7% tax for Active Filers, but a staggering 21% tax for Non-Filers. • Cash withdrawals by a person whose name does not appear on the Active Taxpayers’ List are hit with an automatic 0.8% advance tax. • Commercial importers bringing in Part-III items are hit with a 12% tax rate if they are Non-Filers, compared to only 6% for Active Filers. • Importing pharmaceutical products carries an 8% tax for Non-Filers, which is exactly double the 4% rate applied to Active Taxpayers. • Selling rice, cotton seed, or edible oils comes with a low 1.5% tax for Filers, but a 3% tax for Non-Filers. • Capital gains arising on the disposal of certain debt securities are taxed at 15% for Filers, but double to 30% for Non-Filers. • If you receive dividends from Independent Power Purchasers (IPPs), Filers pay a 7.5% tax while Non-Filers surrender 15%. • Payments made to non-resident sportspersons incur a 15% tax if they are on the ATL, and a massive 30% if they are non-ATL. • The sale of petroleum products is taxed at 12% for Filers and exactly double that at 24% for Non-Filers. • Importing basic goods from Part-I of the Twelfth Schedule costs Active Taxpayers just 1% in tax, while Non-Filers have to pay 2%. • Winning a raffle, lottery, or sales promotion prize costs Non-Filers a whopping 40% in tax, compared to 20% for Filers. • Registering a 1000cc motor vehicle costs Filers just 1% in tax, while Non-Filers are penalized with a 3% tax. • Salaries under Rs. 600,000 are completely tax-free, maintaining a 0% rate regardless of your taxpayer status. • Commercial importers of Part-II goods face a 3.5% withholding tax if they are Filers, but the rate doubles to 7% for Non-Filers. • Purchasing a 1601cc to 1800cc vehicle will cost Non-Filers a 9% tax, which is three times the 3% rate given to Active Filers. • Pensions under 10 million rupees remain 100% tax-exempt for everyone, no matter what your filing status is. • Providing IT and IT-enabled services costs Active Taxpayers just 4% in withholding tax, while Non-Filers must pay 8%. • Winning a prize bond or crossword puzzle means you lose 15% to taxes as an Active Filer, but a massive 30% if you are a Non-Filer. • Buying a high-end 2501cc to 3000cc vehicle leaves Filers with a 9% tax bill, but absolutely punishes Non-Filers with a massive 27% tax rate. • Dividends from Real Estate Investment Trusts (REITs) and general companies cost Active Filers 15% in tax, but Non-Filers lose a massive 30%. • Buyers of 1301cc to 1600cc cars pay a 2% advance tax if they are Filers, but Non-Filers pay exactly triple at 6%. • Profits on debt from mutual funds deriving 50% or more income from debt carry a huge 50% tax for Non-Filers, compared to 25% for Filers. • Companies generating rental income from immovable property pay a 15% tax if they are Active Filers, but face a 30% rate as Non-Filers. • Active Filers importing CKD kits for Electric Vehicles pay a minimal 1% tax, whereas Non-Filers pay double at 2%. • The withholding tax on banking and financial institution profits is set at 20% for those on the Active Taxpayers’ List, but jumps to 40% for those off the list. • Payments to electronic and print media for advertising services are taxed at just 1.5% for Active Taxpayers, compared to 3% for Non-Filers. • Registering a 2001cc to 2500cc luxury vehicle incurs a 7% tax for Active Filers, but a staggering 21% tax for Non-Filers. •

How to File UBO Form on FBR IRIS Portal?

Ultimate Beneficial Ownership (UBO) disclosure is now mandatory in Pakistan as part of efforts to combat money laundering and increase financial transparency. A UBO refers to the natural person who ultimately owns or controls a company or AOP, either directly or indirectly.

Syed Babar
December 20, 2024
Tax Toolkit

In an era of heightened global scrutiny on financial transparency and the fight against illicit financial flows, the concept of Ultimate Beneficial Ownership (UBO) has taken center stage. Pakistan, committed to aligning with international standards and increasing its efforts against money laundering and tax evasion, has mandated the disclosure of UBO information for companies and Associations of Persons (AOPs).

This article serves as a comprehensive guide to understanding UBO in the Pakistani context and navigating the process of filing the required information with the Federal Board of Revenue (FBR) through its IRIS portal.

Understanding Ultimate Beneficial Ownership

Before delving into the filing process, it’s crucial to understand what exactly constitutes a Beneficial Owner (UBO). Simply put, a UBO is the natural person who ultimately owns or controls a legal entity, such as a company or trust.

This ownership or control can be direct, through holding a significant percentage of shares or voting rights, or indirect, through a chain of ownership or other means of control over the entity’s finances, decisions, or affairs. The core principle behind UBO disclosure is to identify the real individuals who stand behind corporate structures, ensuring accountability and preventing the misuse of legal entities for illicit purposes.

The Legal Framework for UBO in Pakistan

Pakistan has progressively integrated the concept of UBO into its legal framework. The Finance Bill 2022 defines a “beneficial owner” as a natural person who ultimately owns or controls a company or AOP, either directly or indirectly, through at least 10% shares or voting rights. This definition also encompasses individuals who exercise ultimate effective control through other direct or indirect means.

Furthermore, the Companies Act, 2017, mandates companies to maintain information about their ultimate beneficial owners, albeit with a threshold of 25% shares or voting rights. These legal provisions underscore the government’s commitment to enhancing transparency within the corporate sector.

Form 45: Declaration of Compliance
To comply with the Companies Act, 2017, companies are required to file a declaration using Form 45 with the SECP. This form ensures that the company has:

Issued notice as per Form 42.
Received declarations from members as per Form 43.
Accurately recorded the particulars of its UBOs.
Authorized the CEO to provide required information under the regulations.

The FBR’s Role and the IRIS Portal

In line with these legal developments, the FBR has mandated the disclosure of UBO information for all companies and AOPs registered with them, with the exception of non-profit organizations where the beneficiaries are the general public. This requirement is primarily fulfilled through the FBR’s online portal, IRIS.

Steps to File the UBO Form on the FBR IRIS Portal

The FBR has streamlined the process of filing the UBO form through its IRIS portal. Here’s a step-by-step guide:

Login to FBR IRIS Portal:
- Visit the official FBR IRIS portal.
- Log in to your account using your company’s or AOP’s credentials (NTN and password).
Navigate to “Applications” Section:
- Once logged in, locate the “Registration” section on the dashboard.
- From the dropdown menu, select “Forms”.
Select “Application Addition of Beneficial Owners U/S 181E”:
- Click on this option to initiate the UBO form filing process.
Provide Required Information:
- Basic Information: Enter the company’s or AOP’s basic details, such as the CNIC/NTN number, name, and registration number.
- Beneficial Owner Details: For each beneficial owner, you will need to provide the following information:
  - Name
  - CNIC/Passport Number
  - Date of Birth
  - Nationality
  - Residential Address
  - Percentage of Ownership or Control
  - Type of Control (e.g., direct shareholding, chain of ownership, joint control, voting rights)
- Supporting Documents (Optional): While optional in the initial steps outlined, be prepared to upload necessary supporting documents such as copies of CNICs, passports, and proof of ownership or control if requested by the FBR.
Review and Submit:
- Carefully review all the information provided for accuracy. Make any necessary corrections before proceeding.
- Once you are satisfied that all the details are correct, submit the form electronically through the portal. You will likely receive a confirmation message or email with a reference number, which you should keep for your records.

Important Considerations for Filing the UBO Form

Filing the UBO form accurately and on time is crucial for compliance. Here are some important considerations to keep in mind:

Accurate Information: Ensure that all information provided about the company/AOP and its beneficial owners is accurate and up-to-date. Any discrepancies can lead to penalties or further scrutiny.
Document Verification: The FBR reserves the right to request additional documentation to verify the information provided. Be prepared to furnish these documents promptly.
Timely Filing: Adhere to any specified deadlines for filing the UBO form. Missing deadlines can result in penalties.
Regular Updates: It’s essential to notify the FBR within 30 days of any changes in the beneficial owner information. The IRIS portal likely has a separate form or process for updating these details.
Secure Credentials: Keep your FBR account credentials secure to prevent unauthorized access.
Monitor Portal: Regularly monitor your FBR IRIS portal for any notifications or updates related to your UBO filing or other compliance requirements.
Stay Updated: Stay informed about any changes or updates to the UBO filing requirements issued by the FBR.

Implications for Companies and AOPs

Compliance with UBO disclosure requirements is not merely a procedural formality. It has significant implications for companies and AOPs operating in Pakistan. Failure to comply can lead to penalties and other legal consequences.⁶ Moreover, providing accurate and up-to-date UBO information enhances the transparency and accountability of businesses, contributing to a more robust and trustworthy business environment. Companies may need to implement internal procedures to identify and verify their UBOs, potentially involving due diligence on shareholders and investors.

The requirement to file the Beneficial Owner form on the FBR IRIS portal is a significant step towards enhancing transparency and combating financial crime in Pakistan. By understanding the concept of UBO, adhering to the legal framework, and diligently following the outlined steps for filing, companies and AOPs can ensure compliance and contribute to a more transparent and accountable economic landscape in the country. Staying informed about the latest regulations and maintaining accurate records are key to navigating this important regulatory requirement successfully.