Under Section 108 of the Pakistan Income Tax Ordinance, 2001, and Chapter VIA of the Income Tax Rules, 2002, businesses engaged in transactions with associated undertakings must maintain robust Transfer Pricing documentation. Javid Law Associates provides end-to-end advisory, benchmarking, and documentation services to ensure your intercompany transactions satisfy the arm's length principle required by the Federal Board of Revenue (FBR).
FBR Transfer Pricing Requirements
The FBR enforces strict compliance protocols for multinational enterprises (MNEs) and domestic companies with related-party transactions. Our legal and tax specialists assist in drafting the mandatory multi-tiered documentation structure, mitigating the risk of audit adjustments, double taxation, and heavy non-compliance penalties.
| Document Type | Applicability Criteria | Filing/Maintenance |
|---|---|---|
| Local File | Transactions with associates exceeding PKR 50 Million | Maintain locally and submit within 30 days of FBR demand |
| Master File | Constituent entity of an MNE Group with consolidated revenue exceeding PKR 100 Million | Maintain locally and submit within 30 days of FBR demand |
| Country-by-Country (CbC) | MNE Group with consolidated annual revenue exceeding EUR 750 Million | File electronically on FBR portal within 12 months of fiscal year-end |
Why Choose Javid Law Associates?
Javid Law Associates has been a trusted partner for corporate legal services in Pakistan since 2004. Operating from F-10 Markaz Islamabad and Bahawalpur, our corporate tax division delivers precise transfer pricing studies using advanced databases for transaction benchmarking. Beyond basic NTN Registration Pakistan and SECP company registration, we provide high-level tax defense, securing exemptions and handling complex appeals before appellate tribunals.
Our Scope of Services
- Preparation and annual updating of the Local File and Master File.
- Benchmarking analysis using international databases to establish arm's length margins.
- Drafting intercompany agreements and Transfer Pricing policies.
- Representation before FBR commissioners during Transfer Pricing audits and appeals.
- Strategic structuring of cross-border transactions to ensure tax efficiency and full regulatory compliance.
Protect your enterprise from compliance risks. Let our dedicated corporate legal team in Pakistan manage your transfer pricing strategy with precision and absolute confidentiality.
Service heading
Mitigate corporate tax audit risks with comprehensive transfer pricing studies, local files, master files, and FBR compliance services.
Estimated duration
3-4 weeks
Price
Rs. 150,000
Requirements
- Consolidated financial statements of the group
- Details of associated enterprises and ownership structure
- Intercompany agreements and transaction ledgers
- Entity-level audited financial statements in Pakistan
- FBR NTN registration details
Key features
- Local File & Master File preparation
- Economic benchmarking & database search
- Intercompany agreement drafting
- FBR transfer pricing audit defense
- Arm's length margin analysis
- Cross-border transaction tax structuring
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.