In Pakistan, multinational enterprises and local groups with cross-border or domestic associated transactions face strict scrutiny from the Federal Board of Revenue (FBR). Under Section 108 of the Income Tax Ordinance, 2001, and Rules 20A to 20I of the Income Tax Rules, 2002, entities must maintain comprehensive transfer pricing documentation to demonstrate that their transactions are conducted at arm's length.
Failing to maintain the required Local File, Master File, and Country-by-Country (CbC) reports can lead to heavy penalties and aggressive tax adjustments by the FBR. Javid Law Associates, a trusted partner for corporate legal services Pakistan since 2004, provides end-to-end advisory to align your transfer pricing policy with local regulations and international OECD guidelines.
Our senior corporate tax team, based in F-10 Markaz Islamabad and Bahawalpur, possesses deep expertise in transfer pricing benchmarking, risk mitigation, and FBR audit representation. Whether your business completed its SECP company registration recently or has been operating for decades, our tailored compliance frameworks protect your business from double taxation and penalty risks.
| Document Type | Filing Threshold | FBR Submission Deadline |
|---|---|---|
| Local File | Transactions exceeding PKR 50 Million | Within 30 days of FBR demand |
| Master File | Group Revenue exceeding PKR 100 Million | Within 30 days of FBR demand |
| CbC Report (Form 3-B) | Consolidated Revenue exceeding EUR 750 Million | Within 12 months from fiscal year-end |
Strategic Benefits of Our Advisory
- Complete alignment with FBR and SECP corporate governance requirements
- Detailed functional, asset, and risk (FAR) analysis to justify pricing structures
- Accurate benchmarking studies utilizing localized and global transactional databases
- Proactive risk assessment to identify and rectify transfer pricing gaps early
- Robust representation during FBR audits and appellate forums
To begin, your business must have active registrations such as an NTN Registration Pakistan. We will review your current transactions, intercompany agreements, and group structures to compile a legally defensible transfer pricing file that guarantees seamless business continuity.
Service heading
Ensure FBR transfer pricing compliance with robust Master File and Local File documentation designed by corporate tax experts in Pakistan.
Estimated duration
3-4 weeks
Price
Rs. 150,000
Requirements
- National Tax Number (NTN) Registration Pakistan and SECP company registration certificate
- Audited financial statements of the Pakistani entity and global group
- Detailed listing of all transactions with associated enterprises
- Existing intercompany agreements and service level contracts
- Organizational structure and ownership shareholding pattern details
Key features
- Preparation of Local File and Master File under FBR guidelines
- Transfer pricing benchmarking analysis using global databases
- Intercompany transaction agreement drafting and review
- Selection and application of Most Appropriate Method (MAM)
- FBR Transfer Pricing Audit risk assessment and advisory
- Country-by-Country (CbC) notification filing representation
About the Author
Written by the expert legal team at Javid Law Associates. Our team specializes in corporate law, tax compliance, and business registration services across Pakistan.