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Filing a return

Withholding Statements Under Section 165

Anyone who collects or deducts tax under the withholding provisions must file a quarterly statement, due on the 20th of April, July, October and January. A statement is required even where nothing was withheld. For a PSEB-registered IT exporter the stakes are higher than the penalty suggests, because section 154A(2) conditions final tax treatment on having filed them.

We do this for clients:Withholding Tax Statements in Pakistan

Where these figures come from

Statutory basis
Income Tax Ordinance, 2001, as amended by the Finance Act 2026, for tax year 2027 (1 July 2026 to 30 June 2027).
Last checked against the statute
by BarrioVibe, which files income tax returns through FBR IRIS.

These figures are an estimate computed from the rates above, not tax advice for your situation. Your return depends on facts a form cannot see, so treat the number as a starting point and speak to us before you file on it.

When each statement is due

Section 165(2). These are quarterly, and the older half-yearly dates that still circulate were replaced by the Finance Act 2020.

Quarter endingDue
31 March20 April
30 June20 July
30 September20 October
31 December20 January

Who actually has to file one

The obligation follows the withholding, so it falls on a person who collects or deducts tax under the relevant Divisions, Chapter XII or the Tenth Schedule. In practice that means anyone who is a prescribed person for section 153 purposes and has been deducting from suppliers or service providers, and any employer deducting from salary under section 149.

The threshold question matters for a small business. A company is a prescribed person at any turnover. An individual or association of persons becomes one only at a hundred million rupees of turnover in any preceding year, raised from fifty million by the Finance Act 2020. So a small firm that has never deducted anything from anyone is generally not filing these, and a company is, from its first quarter.

When the statement is not required at all

The second proviso to section 165 disapplies the section where the information required under sub-section (1) has been furnished under section 165A. That is the banking information provision, so the carve-out is narrow and specific rather than general relief.

Note it is section 165A and not section 165AB. Section 165AB is the Central Data Hub inserted by the Finance Act 2026, requiring banks and electronic money institutions to upload for algorithmic cross-matching, and it does not carry the same disapplication.

Questions

The questionspeople ask

  • When are withholding statements due in Pakistan?

    Quarterly, on the 20th of April, July, October and January, under section 165(2). The half-yearly dates of 31 July and 31 January that still circulate were replaced by the Finance Act 2020.

  • Do I have to file a withholding statement if I deducted nothing?

    Yes. The first proviso to section 165 requires every person within sub-section (1) to file a statement even where no withholding tax was collected or deducted during the period.

  • Who has to file a section 165 statement?

    Anyone collecting or deducting tax under the withholding provisions. In practice a prescribed person under section 153 who has been deducting, and any employer deducting from salary. A company is a prescribed person at any turnover; an individual or association only at Rs 100 million of turnover in a preceding year.

  • What is the penalty for not filing a withholding statement?

    Under entry 1A of the section 182 table, fifty thousand rupees where the tax was paid on time and the statement is filed within ninety days of the due date. Otherwise two thousand five hundred rupees for each day of default, with a minimum of ten thousand.

  • Does a late withholding statement remove me from the ATL?

    No. Section 182A turns on the return under section 114, not on section 165 statements. The consequences are the penalty and, for a PSEB-registered exporter, the section 154A(2) condition.

  • How do withholding statements affect the 0.25% export rate?

    Section 154A(2) makes the export deduction final tax only where the return, the withholding statements for the year, and sales tax returns have been filed where required. A missed statement therefore puts final tax treatment of the export receipt at risk, not just a penalty.

  • Are withholding statements monthly, biannual or quarterly?

    Quarterly. All three figures are in circulation because rule 44 said monthly until SRO 849(I)/2019 made it biannual, and the Finance Act 2020 then made the statute quarterly without conforming the Rule, which still reads biannual today. Section 165(2) fixes the dates in primary law and FBR Circular No. 3 of 2020 confirms the change.

  • Does an employer file anything beyond the quarterly statement?

    Yes. Section 165(6) requires an annual statement for salary deductions, section 165(7) an annual statement within thirty days of the end of the tax year, and section 165(8) a reconciliation statement by the section 118 return due date.

Rather have someone handle it?

We file returns through IRIS every day. If the answer above raises a question about your own case, that is the conversation to have before the deadline rather than after it.

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