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.