NTN and tax registration with FBR: a practical guide

How individuals, firms and companies register with FBR through IRIS, how the Active Taxpayers List works, and when sales tax registration applies.

For most people and businesses in Pakistan, dealing with the tax system starts with registering with the Federal Board of Revenue (FBR). This guide explains how income tax registration works under the Income Tax Ordinance, 2001, which is done through FBR's online portal, IRIS. It covers how registration differs for individuals, associations of persons (AOPs) and companies, and what the Active Taxpayers List (ATL) is. It ends with a short overview of federal sales tax registration under the Sales Tax Act, 1990.

The legal basis

Taxpayer registration is dealt with in section 181 of the Income Tax Ordinance, 2001 ("Taxpayer's registration"). The Active Taxpayers List is set up under section 181A. Returns of income are covered by section 114. The Ordinance is amended regularly, usually through each year's Finance Act. Check the current consolidated text that FBR publishes before relying on any particular provision.

What an NTN is

A National Tax Number (NTN) is the identifier FBR uses for a taxpayer. According to FBR, persons are treated as registered once they are e-enrolled on IRIS. E-enrolment gives you a registration number and a password, and that login is how you file returns online.

  • Individuals: FBR uses the individual's 13-digit Computerised National Identity Card (CNIC) number as the NTN or registration number.
  • AOPs and companies: a separate seven-digit NTN is issued on e-enrolment.

Registering as an individual

An individual registers online through IRIS using the option for unregistered persons. FBR's guidance requires basic personal and contact details, including a mobile number and email address. Both are verified by code during registration, so they should belong to the applicant. Once enrolled, the individual can complete their profile, for example by adding business details if they are a sole proprietor, and file returns of income and wealth statements as required.

Being registered does not mean you have filed. Registration only creates your account. Whether you must file a return, and what reliefs or obligations apply to you, depends on your income and circumstances under the Ordinance.

Registering an AOP (firm or association)

Under the Ordinance, an association of persons includes a firm. A partnership is therefore registered as an AOP in its own right, separately from its partners. Registration is normally done by a principal officer or a member. It generally needs particulars of the AOP, its members and their shares, and its business details. In practice, documents such as the partnership deed and, where applicable, the firm's registration certificate are used. The principal officer's own IRIS profile is usually linked to the AOP's registration.

Registering a company

For companies incorporated with the Securities and Exchange Commission of Pakistan (SECP), the process is now largely joined up. SECP states that NTNs are issued through an integrated SECP–FBR online system, so a new company can obtain its NTN as part of SECP's eServices incorporation process. Once the NTN is issued, the company's principal officer can manage the company's IRIS profile and should make sure its details are complete and up to date. These include its registered address, business activity, directors and bank accounts. Foreign companies with a presence in Pakistan, such as a branch, have their own registration requirements and should take specific advice.

The Active Taxpayers List (ATL)

The ATL is FBR's list of persons treated as active taxpayers, maintained under section 181A. Being on the ATL matters in practice because many withholding tax rates and transaction rules in Pakistan differ depending on whether a person is on the list. (The older statutory terms "filer" and "non-filer" were removed from the Ordinance's definitions by the Finance Act, 2019, though they are still used informally.)

According to FBR's published guidance:

  • a person appears on an ATL if they have filed the return of income for the relevant tax year, and have done so by the due date;
  • a person who files late can be included only after paying the surcharge provided for this purpose (linked to section 182A); and
  • companies and AOPs formed after the end of the relevant tax year are included without a return for that year.

The ATL is published and updated by FBR, and status can be checked through FBR's online services. Because your position on the list affects tax deducted at source, it is worth checking your status after filing. Recent amendments to the Ordinance have also added provisions restricting certain economic transactions by some persons (section 114C). These rules are technical and are still developing, so they should be checked against the current text before any significant transaction.

Sales tax registration: an overview

Sales tax on goods at the federal level is governed by the Sales Tax Act, 1990 and the Sales Tax Rules, 2006, and is administered by FBR. Registration is a separate step from income tax registration, but it is also done through IRIS. FBR's published guidance lists the following categories of persons who are to be registered:

  • importers;
  • wholesalers (including dealers) and distributors;
  • manufacturers, other than those within the "cottage industry" category as defined;
  • retailers, with Tier-1 retailers subject to specific rules;
  • persons required to register under another federal or provincial law for a duty or tax collected as if it were sales tax; and
  • persons making zero-rated supplies, including commercial exporters seeking refunds.

FBR also notes that a person who should be registered but is not may be compulsorily registered after inquiry under the Sales Tax Rules, 2006.

What the IRIS application involves. According to FBR, the applicant gives business and bank account details (a bank account certificate in the business's name), GPS-tagged photographs of the business premises, and electricity or gas consumer details with meter photographs. Manufacturers must also give details and photographs of their machinery and industrial meters. After applying, the applicant must complete biometric verification at a NADRA e-Sahulat centre within the period FBR specifies, currently about a month. Failure to do so can lead to removal from the sales tax Active Taxpayers List. FBR may also carry out post-registration verification.

Services are different. Sales tax on services is largely a provincial matter. Services provided in the provinces are generally dealt with by the relevant provincial revenue authority, while FBR administers sales tax on services in the Islamabad Capital Territory. A business providing services in more than one jurisdiction may need more than one registration.

Practical points

  • Use your own mobile number and email address for IRIS. They are used for verification and for official notices.
  • Keep your IRIS profile up to date, including your address, business details and bank accounts.
  • Registration is only the start. Filing deadlines, withholding obligations and monthly sales tax returns follow from it.
  • Keep copies of all acknowledgements and registration certificates.

Frequently asked questions

Is my CNIC really my NTN?

For individuals, yes. FBR uses the 13-digit CNIC number as the NTN or registration number once you are e-enrolled on IRIS. AOPs and companies receive a separate seven-digit NTN.

Does registering with FBR put me on the Active Taxpayers List?

Not by itself. Generally, you are included on the ATL once you have filed your return of income for the relevant tax year by the due date. Late filers are included only after paying the prescribed surcharge.

Does a new company need to apply separately for an NTN?

Usually not. SECP states that NTNs are issued through its integrated online system with FBR at incorporation. The company should still check and complete its IRIS profile afterwards.

Do I need sales tax registration as well as an NTN?

Only if you fall within a category that must register, or you choose to register voluntarily where that is allowed. Importers, wholesalers, distributors, many manufacturers and certain retailers are among the categories FBR lists. Service providers should also check provincial sales tax rules.

Sources

This guide is general information only and is not legal advice. Tax law and FBR procedures change frequently, often through the annual Finance Act, and your obligations depend on your circumstances. Please take advice on your specific situation.