Filing Multiple Statutory Returns

Introduction

In Pakistan’s corporate environment, businesses must comply with numerous statutory obligations to remain in good legal standing. Among these obligations, filing multiple statutory returns is one of the most critical compliance activities for registered companies, partnerships, and even individual taxpayers operating under different legal frameworks. This comprehensive guide explains the types of statutory returns in Pakistan, their legal basis, timelines, responsible authorities, and the consequences of non-compliance. It’s tailored for business owners, tax consultants, CFOs, and compliance officers to help ensure smooth operations and avoid legal troubles.

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What Are Statutory Returns?

Statutory returns are official submissions that entities must file with regulatory bodies under the applicable laws. These returns ensure that businesses adhere to tax laws, labor regulations, and corporate governance requirements. In Pakistan, these are primarily governed by the Companies Act 2017, Income Tax Ordinance 2001, Sales Tax Act 1990, Employees’ Old-Age Benefits Institution (EOBI) regulations, and Punjab Revenue Authority (PRA) or Sindh Revenue Board (SRB) rules depending on the jurisdiction.

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Major Types of Statutory Returns in Pakistan

1. Income Tax Returns (ITR)

• Filer: Companies, AOPs, and individuals

• Deadline: September 30 (for individuals & AOPs), December 31 (for companies with special tax year)

• Filed With: Federal Board of Revenue (FBR)

• Legal Reference: Income Tax Ordinance 2001

This return includes details of income, expenses, deductions, tax payments, and withholding taxes. Filing accurate ITR is necessary to maintain Active Taxpayer status (ATL) and avoid higher withholding tax rates.

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2. Withholding Tax Statements (Section 165 Statements)

• Filer: All withholding agents (companies, employers, property buyers, etc.)

• Filing Frequency: Monthly

• Deadline: 15th of each month

• Filed With: FBR

• Legal Reference: Section 165 of Income Tax Ordinance 2001

Entities deducting tax at source (e.g., salary, rent, services) must file this statement, disclosing amounts deducted and deposited into the government treasury.

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3. Sales Tax Returns

• Filer: Sales tax registered persons (companies, retailers, importers)

• Filing Frequency: Monthly

• Deadline: 18th of each month (subject to change by FBR)

• Filed With: FBR or Provincial Revenue Authorities (PRA, SRB, KPRA, BRA)

• Legal Reference: Sales Tax Act 1990

Sales tax returns detail output tax collected, input tax claimed, and the net tax payable. Filing ensures the business is eligible for tax credits and is compliant with GST rules.

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4. Federal Excise Duty (FED) Returns

• Filer: Manufacturers and service providers subject to FED

• Filing Frequency: Monthly

• Filed With: FBR

• Legal Reference: Federal Excise Act 2005

Applicable on certain goods and services, the FED return provides tax liability based on production volume or value of services.

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5. Employees’ Old-Age Benefits Institution (EOBI) Returns

• Filer: Employers registered with EOBI

• Filing Frequency: Monthly

• Deadline: 15th of each month

• Filed With: EOBI

• Legal Reference: Employees’ Old-Age Benefits Act, 1976

Employers must contribute a portion of each employee’s salary and report the employee and employer contributions monthly.

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6. Social Security Returns (PESSI, SESSI, etc.)

• Filer: Registered employers

• Filing Frequency: Monthly

• Deadline: Varies by province

• Filed With: Provincial social security institutions

• Legal Reference: Provincial Employees Social Security Ordinance 1965

These returns relate to employee benefits such as medical facilities and injury compensations.

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7. SECP Statutory Returns (Company Filings)

• Filer: Companies registered with SECP

• Filing Frequency: Event-based and annual

• Examples Include:

  • Form A (Annual Return)

  • Form 29 (Change in directors or officers)

  • Form 45 (Change in registered address)

  • Form 3 (Allotment of shares)

• Filed With: Securities & Exchange Commission of Pakistan (SECP)

• Legal Reference: Companies Act 2017

SECP filings maintain the corporate record of the company. Non-filing leads to penalties and potential legal action.

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Importance of Timely and Accurate Statutory Return Filing

Filing statutory returns isn’t just a legal formality—it is a vital part of maintaining corporate health and financial transparency. Timely filing ensures:

• Compliance with laws

• Avoidance of penalties

• Credibility with banks, investors, and government agencies

• Access to government tenders and tax credits

• Maintenance of active taxpayer status

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Tools and Portals Used in Filing Statutory Returns

1. IRIS Portal (FBR)

Used for income tax, sales tax, and withholding tax statements.

2. SECP e-Services Portal

Used to file forms like Form A, Form 29, and others electronically.

3. EOBI Online Portal

Allows employers to submit employee data and make EOBI payments.

4. PESSI/SESSI Portals

Provincial social security return submissions and contribution payments.

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Common Challenges Faced During Filing

• Understanding deadlines for various filings

• Technical issues on government portals

• Incorrect or incomplete data entry

• Misclassification of transactions

• Lack of internal coordination between HR, accounts, and legal teams

• Frequent regulatory updates not being followed

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Penalties for Non-Compliance

Failure to file statutory returns can result in:

In extreme cases, SECP or FBR may initiate legal proceedings, suspend licenses, or deregister companies.

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Best Practices to Ensure Compliance

1. Create a Statutory Calendar

Track all monthly, quarterly, and annual return deadlines in a shared dashboard or Google Calendar.

2. Designate Compliance Officers

Assign a team or professional responsible for compliance filings.

3. Use Accounting Software

Modern ERP tools (e.g., QuickBooks, Xero, SAP) can automate record-keeping, helping in return preparation.

4. Regular Staff Training

Keep your accounting and HR staff up to date with changing regulations.

5. Work With a Compliance Consultant

Outsourcing return filing to experts (like Sterling.pk) reduces risk and ensures filings are accurate and on time.

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Sector-Specific Return Filing Notes

For IT and Software Companies

They must file tax returns and sales tax returns, especially if registered with PSEB or exporting services under zero-rating regime.

For Manufacturing Companies

Must file sales tax and FED returns regularly and declare inventory for valuation.

For NGOs & NPOs

Need to file income tax under Section 100C and regularly update SECP regarding governance and funding sources.

For Freelancers and Consultants

Required to file income tax returns even if they are not registered businesses.

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Filing Multiple Returns for Multiple Entities

If you operate multiple businesses, or have multiple NTNs, each entity must file separate statutory returns. Consolidation is not allowed unless they are legally grouped or structured under a single legal entity.

Also note:

• Sales tax groups must file consolidated returns with proper approvals.

• Holding companies must separately file returns for each subsidiary.

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How Sterling.pk Can Help You Stay Compliant

At Sterling.pk, we understand the burden of managing multiple compliance requirements. Our experienced consultants help:

• Prepare and file all statutory returns on time

• Liaise with FBR, SECP, EOBI, and other authorities

• Provide full documentation support

• Set up statutory calendars for recurring filings

• Represent clients during audits and legal queries

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Conclusion

Filing multiple statutory returns in Pakistan is a complex yet essential task for every business entity. Missing a deadline or filing incorrect data can lead to hefty penalties, reputational damage, or worse—legal shutdowns. This detailed guide gives you an overview of all key filings, authorities, and best practices to stay ahead of regulatory compliance.

By working with compliance experts like Sterling.pk, you ensure peace of mind while focusing on your business growth.