Reintroduction of sales tax on advances: KTBA seeks guidelines on advance invoices’ declaration

KARACHI: Taxpayers in Karachi are grappling with significant challenges in paying sales tax and claiming debit/credit notes, due to lack of necessary amendments after the reintroduction of sales tax on advances.

The issue was raised by the Karachi Tax Bar Association (KTBA) in a letter sent to the Member IR, operations.

The KTBA highlighted that while the concept of sales tax on advances has been reintroduced after a five-year hiatus, the corresponding changes in the IRIS (Inland Revenue Information System) have not been implemented. This oversight has led to numerous technical and mechanical issues for taxpayers.

The reintroduction of sales tax on advances came through changes in the definition of “time of supply” under Section 22(44)(a) of the Sales Tax Act, 1990. However, the IRIS system has not been updated to accommodate these changes, creating a disconnection between the law and its practical implementation.

It said that the taxpayers were unable to declare and pay sales tax on advance receipts in current returns besides facing difficulties in taking due credit through adjustments as previously practiced.

Furthermore, it said that over the past year, the Federal Board of Revenue (FBR) has implemented significant restrictions on the declaration of credit notes through the IRIS portal.

Under these limitations, suppliers cannot declare credit notes independently without buyers first declaring debit notes.

The letter said the debit notes require reference to IRIS-assigned invoice numbers and the portal calculating credit note amounts based on the difference between actual and adjusted invoice amounts.

A six-month time limit for suppliers to issue credit notes after declaring sales tax invoices and the inability to declare credit notes against unregistered buyers in Sales Tax Returns (STRs) have substantially altered the process of handling credit and debit notes within the tax system.

Consequently, the implications of the above rule are not possible, and taxpayers will remain unable to declare and pay sales tax on advance receipts in their current return and take due credit through adjustments as practiced earlier.

Keeping said in view, the KTBA has requested clarification and guidelines on how to declare advance invoices and make necessary adjustments in tax returns, especially for actual supplies or cancellations.

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