The Pakistan Tax Bar Association (PTBA) has urged the Federal Board of Revenue (FBR) to withdraw the newly introduced Rs. 25,000 surcharge being imposed on late tax filers seeking inclusion in the Active Taxpayers List (ATL) for Tax Year 2025.
In a letter addressed to FBR Chairman Rashid Mahmood Langrial, the association stated that tax professionals across Pakistan have raised serious concerns over the implementation of the enhanced surcharge under Section 182A of the Income Tax Ordinance, which was introduced through the Finance Act, 2026.
According to the PTBA, the FBR’s IRIS portal is currently requiring individual taxpayers to pay the Rs. 25,000 surcharge before they can regain ATL status for Tax Year 2025. The association argues that this requirement is legally questionable because the amendment creates a new financial liability and should not be applied retrospectively.
FBR Announces New Property Valuation Rates for Islamabad
The PTBA maintained that under well-established legal principles, tax laws imposing new liabilities generally apply only to future tax years unless Parliament explicitly provides for retrospective implementation. It argued that no such provision exists in the Finance Act, 2026.
To support its position, the association referred to previous judicial interpretations of amendments made under the Finance Act, 2002, where courts ruled that similar changes could only apply prospectively rather than to earlier assessment years.
The PTBA has requested the FBR to immediately instruct Pakistan Revenue Automation (Private) Limited (PRAL) to remove the IRIS system requirement that forces taxpayers to pay the enhanced surcharge for Tax Year 2025.
As an alternative, the association proposed postponing the implementation of the new surcharge until Tax Year 2026, allowing the amended law to take effect prospectively and in accordance with established legal principles.
The FBR has not yet issued an official response to the PTBA’s request. Taxpayers and tax practitioners are now awaiting clarification on whether the surcharge requirement will be revised or remain in force.
