PTBA concerned at gaps in FBR’s digitised tax infrastructure

KARACHI: The Pakistan Tax Bars Association (PTBA) has raised serious concerns about systemic gaps in the FBR’s digitized tax infrastructure, calling for urgent policy-level intervention to bring the system in line with statutory law.

In a letter sent to the chairman FBR, the PTBA has identified several critical areas where the FBR’s digital framework, particularly the IRIS portal, fell short of both legal requirements and taxpayer facilitation standards.

The PTBA pointed out the implementation of SRO 297(I)/2023, along with SROs 55, 164, 350, and 69, saying that the system’s design did not fully reflect the intent and provisions of these instruments.

“The integrity of the statutory framework must always inform and govern system design, and not the reverse,” the letter said, warning that compliance outcomes being inadvertently shaped by technical limitations rather than law pose a serious threat to taxpayer confidence and the rule of law.

The bar also highlighted that despite the incorporation of HS Codes within the return framework, the rollout has not been matched by corresponding integration within the invoicing system.

Synchronization between Annexures A, B, C, and H1 remains incomplete, creating data asymmetries that could expose law-abiding taxpayers to unwarranted audits, urging the FBR to establish and communicate a clear, time-bound implementation roadmap to complete this integration.

It said that the lack of a formalised JSON-based amendment workflow has left taxpayers dependent on informal interventions, recommending that a formal correction and rectification mechanism be established as a policy priority and integrated directly within IRIS, rather than operated as a separate system.

The letter also raised concerns about taxpayers’ inability to access their own digital compliance records, including system logs, modification histories, and data access records, when subjected to audit or enforcement proceedings based on system-generated data.

“Providing taxpayers with meaningful access to their own digital compliance records is not merely a matter of good administrative practice; it is a requirement of procedural fairness and natural justice,” the PTBA said, urging that a structured and secure access mechanism should be developed as part of the digital governance framework.

It also stressed the need for the development and integration of a formal Customer Relationship Management (CRM) module directly within the IRIS portal to taxpayers and practitioners to raise, track, and resolve technical and system-related issues through a transparent, multi-tier, and fully auditable framework.

The proposed CRM would feature taxpayer-initiated issue logging with unique tracking references, direct engagement with designated PRAL technical representatives, a multi-tier escalation pathway to senior governance levels, full audit trails visible to initiating taxpayers in real time, and periodic performance reporting to the FBR leadership and Parliamentary committees, it added.

Copyright Business Recorder, 2026