
Electronic invoicing guide
Pakistan

Digital reporting requirements
Real Time Reporting.
Obligatory
Mandatory for B2B and B2C
As of February 1, 2024, manufacturers, importers, wholesalers, dealers, and distributors within this sector are mandated by the Pakistan Federal Board of Revenue (FBR) to adopt electronic invoicing for all sales tax transactions.
Registered persons notified by FBR will issue electronic sales tax invoices in JSON format for every taxable supply in real time. These persons must integrate their PoS, ERP, or any other invoicing system with FBR through a licensed integrator. Until the FBR approves the list of licensed integrators, registered persons dealing with FMCG have to integrate their e-invoicing system with the FBR system without licensed integrators.
B2C fiscal registers
Taxpayers, known as ‘integrated suppliers’ must shortly install VAT fiscal registers for B2C invoicing. This includes: Manufacturers, importers, wholesalers and distributors of fast-moving consumer goods. FBR will notify affected suppliers.
Fiscal registers will be provided by certified distributors. These registers will provide automated daily direct reporting to the FBR. But the integrated supplier shall allow physical and online remote access to the records, systems, logs and documents maintained in electronic form.
B2B e-invoicing
The FBR is also planning to introduce a centralized B2B e-invoicing platform. The will require a JSON file submission, with the return of a unique code to be embedded with the e-invoice before submission to the customer.
Authority
The Federal Board of Revenue (FBR).
Platform
The Federal Board of Revenue (FBR) Platform.
Format
JSON.
Storage time
6 years.
Reporting and processes
Processes
Prescribed persons will install an “e-invoicing system” provided by an FBR-licensed person.
Integrated suppliers will issue real-time, verifiable electronic sales tax invoices for every taxable supply following the information required under section 23 of the Sales Tax Act, 1990 (ST Act).
Integrated suppliers will permit physical and online remote access to the records, systems, logs, and documents maintained in electronic form as needed by the FBR’s prescribed officer.
Prescribed persons will face penalties for non-compliance with these rules.
However, they may continue issuing paper invoices if the Commissioner of Inland Revenue permits them to do so.
The conditions mentioned above and requirements will also apply to registered buyers who receive electronic invoices from integrated suppliers.
Upcoming legislative changes
For the time being, no legislative changes are foreseen.
Links of Interest and documents
https://fbr.gov.pk/faqs/173967/173969
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