Punjab Finance Bill 2026: Proposed Changes In Punjab Sales Tax On Services Act, 2012

The Punjab Finance Bill, 2026 proposes a focused but important set of amendments in the Punjab Sales Tax on Services Act, 2012. The Bill has been tabled before the Provincial Assembly of the Punjab and the proposed changes are expected to take effect from 1 July 2026, subject to enactment. The amendments mainly target input tax claims, active taxpayer compliance, reduced rate services, electronic invoicing, penalties, and registration-linked enforcement.

For businesses operating in Punjab, these proposals are not merely rate changes. They may affect vendor onboarding, monthly sales tax cash flows, capital expenditure planning, POS/billing systems, license renewals, public-sector contracts and overall PRA compliance discipline.

Active taxpayer status to become a key compliance condition

The Bill proposes to substitute the definition of “active taxpayer” in section 2 of the Punjab Sales Tax on Services Act, 2012. Under the proposed definition, a registered person will not be treated as active where its registration has been suspended or blacklisted by PRA, or where it has failed to file returns by the due date for the last two consecutive tax periods.

This change becomes more significant because it is linked with input tax adjustment. A new clause is proposed to be inserted in section 16B, under which input tax will not be admissible on goods and services received against invoices issued by persons who are not appearing on the active taxpayer list of PRA or FBR.

In practical terms, a supplier’s non-active status may now directly affect the customer. Even if tax is charged on the invoice, the buyer may not be able to claim input tax if the supplier is not appearing on the relevant active taxpayer list. This makes vendor screening and periodic ATL verification a necessary part of the procurement and accounts payable process.

Proposed change Practical impact Who should review
Active taxpayer definition revised Two consecutive late/non-filed returns may affect ATL status All PRA-registered persons
Input tax blocked on non-ATL invoices Tax charged by non-active suppliers may become a cost Businesses claiming input tax
PRA/FBR ATL relevance introduced Vendor verification becomes operationally important Procurement and finance teams

Input tax adjustment proposed to become more restrictive

The Bill proposes to amend section 16C by reducing the general input tax adjustment limit from 90% to 80% of output tax. This means that a registered person may be required to discharge at least 20% of its output tax in cash during a tax period, even where sufficient input tax is otherwise available.

A new section 16CC is also proposed for input tax on capital goods, machinery and fixed assets. Under this proposal, input tax on such items will be adjustable in twelve equal monthly instalments, subject to the restrictions contained in section 16B. This may have a direct cash-flow impact on businesses undertaking capital expenditure, including hotels, healthcare facilities, gyms, laundries, cold storages, equipment rental businesses and other service providers investing in plant or fixed assets.

The Bill also proposes to insert section 16CCC, empowering PRA to establish a risk-based input tax evaluation system. Under this system, PRA may identify, evaluate and monitor risks associated with input tax claims, adjustments, credits and refunds; maintain risk profiles of taxpayers, suppliers and transactions; defer claims pending verification; disallow claims fully or partly; require further evidence; or select cases for audit or investigation. The proposed section also provides that no adverse action shall be taken without an opportunity of being heard, and an aggrieved person may apply to the Commissioner, who is required to decide the application within thirty days.

Area Existing position Proposed position
General input adjustment cap Up to 90% of output tax Up to 80% of output tax
Capital goods and fixed assets Generally claimable subject to normal rules Spread over 12 monthly instalments
Input tax scrutiny Existing verification/audit framework Risk-based evaluation and profiling system

Reduced rate services proposed to move from 5% to 8%

A major rate-related proposal is the increase in reduced rate from 5% to 8% for several services listed in Part III of the Second Schedule. The Bill specifically proposes substitution of the word “Five” with “Eight” at various entries, including S/N 2, S/N 4(a), S/N 10, S/N 12, S/N 14, S/N 15(a), S/N 18, S/N 19, S/N 22(a), S/N 25, S/N 30 and S/N 32.

This change will affect a wide range of consumer-facing and professional services. Businesses covered by these entries will need to update billing systems, contracts, quotations, POS configurations and customer communication before implementation.

Service category Existing rate Proposed rate
Marriage halls, lawns, pandals, shamianas and catering services 5% 8%
Restaurants and similar food outlets — digital payment clause 5% 8%
Tour operators and travel agents 5% 8%
Property dealers and realtors 5% 8%
Architects, town planners, landscapers and interior designers 5% 8%
Rent-a-car services provided to end consumers 5% 8%
Healthcare, gyms, fitness, indoor sports, amusement and recreation 5% 8%
Laundries and dry cleaners 5% 8%
Accountants, auditors, tax consultants and corporate law consultants 5% 8%
Warehouses, depots, cold storages and storage space 5% 8%
Rental of construction equipment, generators, containers and related items 5% 8%
Apartment-house management, real estate management and rent collection 5% 8%

For advisers and professional firms, the proposed increase in the reduced rate for accountancy, audit, tax consultancy and corporate law consultancy services is particularly relevant, as it may require revision of fee notes, engagement terms and billing templates.

Hotels and restaurants: digital payments remain incentivised, but at a higher reduced rate

The Bill proposes to revise the rate structure for hotels, motels and guest houses under S/N 1 of Part III of the Second Schedule. Under the proposed structure, where payment is received through debit or credit cards, mobile wallets or QR scanning, the rate will be 8% without input tax adjustment. For other cases, the rate will be 16%.

For restaurants and similar food outlets covered under S/N 4(a), the digital payment reduced rate is proposed to increase from 5% to 8%, while the higher rate for other modes of payment continues to remain relevant. The policy direction is clear: Punjab continues to encourage documented and digital payments, but the concessionary rate is being rationalized upwards.

Service Digital payment Other payment modes
Hotels, motels and guest houses 8% without input adjustment 16%
Restaurants and similar food outlets 8% under digital payment clause 16% where applicable

Hospitality businesses should review their POS systems, payment gateway mapping, menu pricing, invoice formats and customer-facing tax disclosures to ensure correct application of the proposed rates from the effective date.

Foreign exchange services proposed to be brought into the tax net

The Bill proposes to omit S/N 25 from the First Schedule, which is linked with foreign exchange dealers, exchange companies and money changers. Correspondingly, a new S/N 35 is proposed to be inserted in Part III of the Second Schedule for foreign exchange services.

Under the proposed entry, foreign exchange services provided by any person, including an exchange company, forex dealer and money changer, will be taxable at 3% without input tax adjustment. The rate is proposed to apply to services involving consideration of spread charges permitted by the State Bank of Pakistan in relation to buying and selling of foreign currencies.

Service Proposed tax treatment Tax base
Foreign exchange services 3% without input tax adjustment Spread charges permitted by SBP

This is a significant sector-specific change. Exchange companies, forex dealers and money changers may need to review registration status, invoicing mechanism, tax computation on spread, accounting treatment and return filing requirements.

Event management services proposed to be separately taxed

The Bill proposes to remove the expression relating to event management services from S/N 9 and insert a separate new S/N 36 in Part III of the Second Schedule.

Under the proposed new entry, event management services covering the whole range and variety of such services, regardless of separate or individual classification, will be taxable at 8% without input tax adjustment. This separate entry appears to remove ambiguity and place event management services clearly within the reduced-rate taxable framework.

Service Existing treatment Proposed treatment
Event management services Covered within broader description Separate entry at 8% without input adjustment

Event managers should review service agreements, composite billing, reimbursements, vendor arrangements, and whether the proposed 8% applies to their full event management offering.

Penalties proposed to be substantially increased

The Bill proposes significant increases in penalties under section 48(2). At S/N 5, relating to failure to produce records or information despite notice, the penalty is proposed to be increased separately for individuals and for companies/AOPs. For individuals, the penalty may go up to Rs. 100,000 for the first default and Rs. 100,000 for each subsequent default. For companies and AOPs, the penalty may go up to Rs. 500,000 for the first default and Rs. 500,000 for each subsequent default.

The Bill also proposes penalty increases for defaults relating to electronic invoice monitoring, failure or refusal to issue tax invoices, and non-compliance with e-invoicing requirements. In certain cases, penalties are proposed to increase up to Rs. 500,000 and Rs. 1 million.

Default area Existing penalty Proposed penalty
Failure to produce records Existing lower slabs Up to Rs. 100,000 for individuals; up to Rs. 500,000 for company/AOP
Interference with electronic invoice monitoring Rs. 100,000 per act Rs. 500,000 per act
Failure/refusal to issue tax invoice Rs. 20,000 / Rs. 50,000 Rs. 500,000 / Rs. 1,000,000
E-invoicing non-compliance Up to Rs. 100,000, minimum Rs. 25,000 Up to Rs. 500,000

The proposed increases indicate that PRA is moving towards stricter enforcement in areas where documentation, invoicing and system integration are involved. Businesses should therefore review record retention, tax invoice issuance, e-invoicing compliance and response protocols for PRA notices.

License renewals and public contracts may depend on PRA registration and ATL status

One of the most important administrative proposals is the substitution of section 76A. Under the proposed provision, PRA may require licensing authorities, permission/NOC issuing authorities and other competent authorities not to issue or renew licenses, permissions or NOCs for taxable service activities unless the applicant proves that it is registered under the Act and appears on PRA’s active taxpayer list.

The same proposed section also covers public procurement. A procuring agency may be restrained from awarding or renewing a contract constituting taxable services unless the bidder, contractor, supplier or consultant is registered and appears on PRA’s active taxpayer list. A newly established business is proposed to be exempt from this requirement for six months from the date of registration.

Area Proposed condition Practical impact
License, permission or NOC PRA registration and ATL status Non-compliance may affect renewal
Public-sector contracts Registered and active taxpayer status Non-active bidders may be restricted
Newly established businesses Six-month relaxation Temporary compliance window

This proposed amendment may make PRA compliance a business continuity issue. Licensed service providers and businesses dealing with public-sector entities should ensure that their registration and ATL status remain intact at all times.

Other administrative amendments

The Bill also proposes certain administrative amendments. Section 5(3) is proposed to be amended by inserting the words “First or”, so that amendments in the First Schedule may also be covered in the relevant legislative placement process.

Section 56(1) is proposed to be amended by replacing “Authority” with “Commissioner” and omitting the requirement of notification in the official Gazette. This relates to access powers concerning premises, stocks, accounts and records. Section 60(1) is also proposed to be amended by increasing monetary thresholds relating to adjudication powers, with “ten” being substituted by “fifty” and “five” being substituted by “twenty-five”.

Provision Proposed amendment Likely effect
Section 5(3) “First or” inserted First Schedule amendments also covered
Section 56(1) Commissioner substituted for Authority Access powers streamlined
Section 60(1) Adjudication limits enhanced Larger cases may be handled at field level

These changes are administrative in nature but should not be ignored. They indicate a broader policy direction towards more direct field-level enforcement and faster administrative action.

Practical action points for businesses

Businesses should start by checking their own PRA filing status because two consecutive missed returns may affect active taxpayer status. They should also build PRA/FBR ATL checks into vendor onboarding and invoice processing, as input tax on invoices from non-active suppliers may become inadmissible.

Finance teams should remodel monthly sales tax cash flows based on the proposed 80% input adjustment cap and the twelve-month spreading of input tax on capital goods, machinery and fixed assets. Businesses planning significant capital expenditure should factor this delayed recovery into their working capital forecasts.

Affected service providers should update their billing systems, POS configurations, customer contracts and pricing models for the proposed rate changes. Particular attention should be given to hotels, restaurants, event managers, exchange companies, professional firms, warehouses, property-related services and equipment rental businesses.

Finally, businesses dealing with licensing authorities or public-sector contracts should ensure continuous PRA registration and ATL status, as non-compliance may now affect license renewals, permissions, NOCs and contract eligibility.

Conclusion

The Punjab Finance Bill, 2026 proposes a clear shift towards stricter documentation, active taxpayer verification, controlled input tax adjustment and stronger PRA enforcement. While the rate increases will be immediately visible for several sectors, the deeper impact lies in the proposed input tax restrictions, risk-based evaluation system, higher penalties and registration-linked controls.

Businesses operating in Punjab should review these proposals early, assess their sector-specific impact and update internal tax compliance processes before the proposed effective date of 1 July 2026. Since these amendments are still proposals, the final legal position should be confirmed once the Punjab Finance Act, 2026 is enacted.

The Sindh Finance Bill, 2026 proposes a series of amendments in the Sindh Sales Tax on Services Act, 2011. Unlike the major structural overhaul introduced last year through the shift towards a CPC-based framework, the current proposals are more focused on procedural tightening, digital compliance, appellate and recovery management, refinement of exemptions and sector-specific rate rationalization.
The proposed changes should be read as part of SRB’s continuing move towards broader documentation, clearer classification of services, stronger invoicing controls and more structured enforcement. The comments below are based on the Sindh Finance Bill, 2026 presently available and may require reconsideration once the Finance Act is finally enacted.

De-registration and continuation of past liabilities

One of the important procedural amendments proposed through the Bill relates to section 25A of the Act dealing with de-registration. Presently, the law provides a timeline of three months for disposal of a de-registration application, subject to further extension in prescribed cases. The Bill proposes to enhance this period to one hundred and eighty days.
The Bill also proposes to clarify that the obligations and liabilities of a person in respect of the period during which taxable services were provided or rendered shall not be affected merely because such person has applied for de-registration or has ceased to be a registered person.

Area Existing position Proposed position
De-registration timeline Three months, subject to extension in prescribed cases One hundred and eighty days
Past liabilities Not expressly clarified in the same manner Liabilities for taxable period to remain enforceable despite de-registration

This proposed amendment appears to be enforcement-oriented. It seeks to ensure that de-registration does not extinguish past tax obligations. Accordingly, where taxable services were provided during the period of registration, SRB may continue to examine returns, tax payments, reconciliations, assessments and recovery proceedings relating to such period.

Digital compliance and software-level accountability

The Bill proposes to insert a specific penalty for any person who designs, develops, customizes or supplies invoicing software which enables issuance of invoices not conforming to the requirements prescribed under rule 29(1) of the Sindh Sales Tax on Services Rules, 2011 or rule 6 of the Sindh Sales Tax Special Procedure (Online Integration of Businesses) Rules, 2022.
The proposed penalty may extend up to Rs. 1 million, subject to a minimum penalty of Rs. 100,000.

Proposed offence Proposed penalty
Designing, developing, customizing or supplying invoicing software enabling issuance of non-compliant invoices Up to Rs. 1 million, subject to minimum penalty of Rs. 100,000

This is a notable development because the compliance exposure is proposed to be extended beyond registered taxpayers to software developers, ERP vendors, POS solution providers and other persons involved in providing invoicing systems. Businesses using customized ERP or POS solutions would need to ensure that their systems are capable of issuing invoices strictly in accordance with SRB’s prescribed format and online integration requirements.

Display of tax-related notices or information

The Bill proposes to insert a new provision empowering the Commissioner to require a registered person to display any notice, message or information through print or multimedia at a conspicuous place in its premises accessible to the general public.
This proposed amendment appears to create a customer-facing compliance obligation. It may be relevant for businesses dealing directly with consumers, including restaurants, hotels, salons, clinics, educational institutions, retail service outlets and similar establishments. The purpose appears to be public awareness in relation to invoicing, tax collection or other tax-related matters.

Appellate inquiry and recovery protection

The Bill proposes to prescribe a sixty-day time limit for completion of an inquiry ordered by the Commissioner (Appeals). This appears to be a procedural amendment aimed at reducing delays in appellate proceedings where factual verification is required.
The Bill also proposes an important amendment in section 66 relating to restriction on recovery during appellate proceedings. Presently, where an appeal is pending before the Commissioner (Appeals), recovery protection is available subject to payment of 10% of the tax due. The Bill proposes to extend this protection to appeals before the Appellate Tribunal as well; however, the amount required to be paid is proposed to be increased from 10% to 20% of the tax due.

Area Existing position Proposed position
Inquiry ordered by Commissioner (Appeals) No specific sixty-day completion period in the proposed manner Inquiry to be completed within sixty days
Recovery protection Available at Commissioner (Appeals) stage subject to payment of 10% of tax due Proposed to extend to Tribunal appeals, subject to payment of 20% of tax due

This proposed amendment would be relevant for taxpayers contesting SRB demands. While the protection against recovery is proposed to be extended up to the Tribunal stage, taxpayers would need to consider the higher 20% payment requirement while planning appeals and stay / recovery strategy.

Confidentiality and disclosure of taxpayer information

The Bill proposes to insert a new provision dealing with confidentiality and disclosure of taxpayer information. Under the proposed amendment, particulars contained in statements, returns, accounts, documents, evidence, affidavits, depositions, assessment records or recovery proceedings are to be treated as confidential.
However, disclosure may be made to persons acting in execution of the Act and to Federal or Provincial Government departments or authorities where such disclosure is authorized under law or made under information-sharing arrangements.
This amendment appears to provide statutory cover for inter-agency sharing of taxpayer information. While confidentiality is recognized, the proposed provision may facilitate cross-verification of data between SRB, FBR and other governmental or regulatory authorities.

Refinement of exemptions under the First Schedule

The Bill proposes certain amendments in the First Schedule dealing with exempt services. These amendments appear to refine the scope of exemption in selected areas rather than introducing a broad exemption regime.

Service / area Existing position Proposed change
Storage and warehousing services Exemption available for services relating to food and agricultural commodities Expression proposed to be replaced with food grains and fresh vegetables and fruits not subjected to further processing
Reinsurance services Insurance and pension services exempt in specified cases, while reinsurance services are generally excluded Specific exemption proposed for reinsurance relating to crop insurance and marine insurance for exports
Education services Threshold-based exemption framework already exists Exemption framework proposed to be refined

Storage and warehousing services

Presently, exemption is available for storage and warehousing services where such services are provided or rendered in relation to food and agricultural commodities. The Bill proposes to substitute the expression with food grains and fresh vegetables and fruits not subjected to further processing.
The proposed wording appears to narrow the scope of exemption. Storage of processed, packaged, preserved or value-added food products may therefore require separate examination for taxability.

Reinsurance services

The Bill proposes to insert a specific exemption for reinsurance services relating to crop insurance and marine insurance for exports. Under the existing framework, insurance and pension services are exempt in specified cases; however, reinsurance services are generally excluded.
The proposed amendment appears to extend the benefit of exemption to reinsurance arrangements connected with crop insurance and export-related marine insurance. Insurers and reinsurers would need to maintain proper documentation to establish that the reinsurance service is directly linked with the specified insurance product.

Education services

The exemption framework for education services is also proposed to be refined. The Bill continues the threshold-based approach whereby education services remain exempt where the fee or charges do not exceed Rs. 500,000 per annum per student. Where the fee or charges exceed the threshold, the service is proposed to fall under the reduced-rate framework.
Educational institutions would need to review their fee structure on a student-wise annual basis. Admission fee, annual charges, laboratory fee, examination fee, technology fee and other mandatory recoveries may become relevant for determining whether the threshold is crossed.

Sector-specific rate and classification amendments

The Bill proposes several amendments in the Second Schedule dealing with reduced-rate services. These changes are sector-specific and should be reviewed along with the general condition that input tax adjustment is generally restricted for services falling under Part-II of the Second Schedule.

Service Existing / general position Proposed rate / mechanism
Ready-mix concrete services Covered within the broader CPC-based framework 8%
Dredging, rock and silt removal Classification may require reference to relevant CPC entry 8%
Construction services by property developers or promoters Generally percentage-based reduced-rate framework Rs. 100 per square yard of land and Rs. 50 per square foot of constructed covered area
Insurance agency services Insurance brokerage and agency services presently covered together 2%
Insurance brokerage services Insurance brokerage and agency services presently covered together 3%
Legal, tax consultancy and insolvency services Professional services covered under reduced-rate framework 8%
Repair services of other goods Covered under repair / maintenance framework depending on classification 8%
Education services exceeding threshold Reduced-rate framework applies where exemption threshold is crossed 3%
Educational support services Separate classification under CPC framework 5%
Beauty and physical well-being services Reduced-rate framework exists 8%
Freight / transportation entries Existing reduced-rate freight entries contain exclusions Petroleum oil transportation through oil tankers proposed to be specifically carved out
Freight forwarding services Fixed / reduced-rate treatment linked with specified documentation Restrictive wording proposed to be omitted

Ready-mix concrete and dredging services

Ready-mix concrete services are proposed to be specifically taxed at 8%. Similarly, services of dredging, rock and silt removal are proposed to be brought within a specific reduced-rate entry at 8%.
These proposed entries may provide clearer classification for infrastructure, construction, port, marine and related project services. However, businesses providing such services should also consider the input tax restriction attached to reduced-rate services.

Construction services by property developers or promoters

One of the more significant proposed amendments relates to construction services provided or rendered by property developers or promoters. Instead of a conventional percentage-based rate, the Bill proposes an area-based mechanism.

Construction service Proposed rate
Construction services by property developers or promoters Rs. 100 per square yard of land
Construction services by property developers or promoters Rs. 50 per square foot of constructed covered area

This proposed change may have material implications for the real estate and construction sector. Further clarity may be required on its application to ongoing projects, phased developments, revised layouts, cancellation of bookings, distinction between land and construction components and timing of chargeability.
Property developers and promoters would need to review customer agreements, booking arrangements, project documentation and tax clauses in light of the proposed mechanism.

Insurance brokerage and agency services

The Bill proposes to separate the rate for insurance agency services and insurance brokerage services. Insurance agency services are proposed to be taxed at 2%, whereas insurance brokerage services are proposed to be taxed at 3%.
This proposed distinction would require insurance companies, agents and brokers to correctly identify the nature of service in agreements, commission statements and tax invoices. Misclassification may result in rate disputes.

Professional services: legal, tax consultancy and insolvency

The Bill proposes to refine the reduced-rate entry for legal, tax consultancy and insolvency-related services. Legal services, tax consultancy and preparation services, and insolvency and receivership services are proposed to be taxed at 8%.
This amendment would be relevant for law firms, tax consultants, professional advisory firms and insolvency professionals. Since reduced-rate services generally carry restrictions on input tax adjustment, the effective tax cost may need to be considered while reviewing fee arrangements, retainerships, reimbursements and inter-provincial service arrangements.

Education and educational support services

The Bill proposes that education services exceeding the threshold of Rs. 500,000 per annum per student would be taxed at 3%. Educational support services are proposed to be taxed separately at 5%.

Service Proposed rate Comment
Education services where fee / charges exceed Rs. 500,000 per annum per student 3% Applies where exemption threshold is crossed
Educational support services 5% Separately classified from core education services

This distinction would require educational institutions and service providers to carefully classify core education services, other education and training services and educational support services.

Repair services and personal care services

Repair services of other goods are proposed to be taxed at 8%. This may be relevant for service providers engaged in repair and maintenance activities where the service does not fall under a more specific classification.
Beauty and physical well-being services are also proposed to be taxed at 8%. This would be relevant for salons, beauty clinics, wellness centres, spas, grooming services and similar establishments. Input tax restrictions under the reduced-rate regime would need to be considered while reviewing pricing and invoicing.

Transportation and freight-related services

The Bill proposes amendments in transportation and freight-related entries, including a specific carve-out for transportation of petroleum oils through oil tankers from the relevant reduced-rate freight entry.
The practical impact would depend on the enacted wording and its interaction with the existing transportation entries. However, the proposed change may be relevant for oil marketing companies, refineries, petroleum logistics providers and oil tanker operators.
The Bill also proposes changes relating to freight forwarding services by omitting certain restrictive wording from the relevant condition. The final enacted wording would determine whether the scope of the fixed / reduced-rate treatment is broadened or otherwise modified.

Conclusion

The Sindh Finance Bill, 2026 does not appear to introduce a broad structural change comparable to the transition towards the CPC-based framework introduced earlier. Instead, the proposed amendments are more targeted and compliance-focused.
The key themes emerging from the Bill are digital compliance, extended accountability, greater recovery discipline, wider data sharing, refinement of exemptions and sector-specific rationalization of reduced-rate services. Businesses operating in affected sectors should review the proposed amendments in light of their invoicing systems, contracts, fee structures, service classifications, input tax position and ongoing litigation or recovery exposure.
The above comments are based on the Sindh Finance Bill, 2026 and the final position may change at the time of enactment.