DIFFICULTIES BEING FACED BY BUSINESS ENTERPRISES DUE TO EXCESSIVE / PRIMITIVE REGULATIONS (REGISTRATION/ APPROVAL/ NOCS /

LICENSES ETC)

Sr. Type Name of Specific Regulatory Nature of Difficulty Proposal for Simplification /
No. of Regulatory Requirements Causing (d) Elimination
Busin Dept. / Agency Difficulty (e)
ess (b) (c)
(a)
It is recommended that there should be
Companies specially trans-
a single tax collection authority to
provincial Cos. have to deal
provide one window solution to
with multiple tax authorities
All Federal and business authorities.
on conflicting issues such as:
1 Provincial Tax Dealing with Multiple Tax Authorities
 WPPF
Authorities Any disputes amongst Provincial /
 WWF
Federal authorities should be resolved
 Provincial Sales Tax
Automobile Manufacturing

fir creating administratively conducive

Laws
business environment.
All Provincial The requirements of laws differ under Provincial laws should be consistent
Inconsistency amongst
2 Tax Collecting each provincial acts. and harmonized for ease of
Provincial Laws
Authorities compliance.
The tax laws are
complicated which cause
administrative hassles. Tax laws should be simplified to ensure
Examples are as follows: ease of compliance.
Federal Board of (Alternate Corporate Tax) 17% after
3
Revenue  Tax payers have to  Complex Tax Structure
accounting profit after adjustment
compare their normal Progressive Taxation – it is against
tax liability with ACT and Tax is on revenue
Minimum tax.

Due to manual and complex
requirements of tax
authorities, taxpayers face
All Federal and many difficulties such as
4 Provincial Tax multiple manual audits by
Authorities different authorities and
departments, manual
processing of refunds and
exemption certificates.
Automobile Manufacturing
Repayment / drawback of
custom duty on exports to
Afghanistan is subject to the
following conditions, in
accordance with Para 7(2)
(c) of Export Policy Order
2016:
FBR and
5 Ministry of "The proof that goods
Commerce exported from Pakistan
have reached Afghanistan
shall be verified on the basis
of a “copy” of import
clearance documents by
Afghan Custom Authorities
across the border."
Aut
6 State Bank of Foreign Exchange Delay in obtaining approvals and Streamline
These can be mitigated through
adopting automation of systems
such as.
 Tax Audits through e-examination
Simplified, electronic, paperless
of data.
procedures should be introduced for
 Processing of Tax refunds through
ease of doing business.
online records of tax collected /
withheld.
 Automated issuance of tax
withholding exemption certificates
on sale of goods and import of raw
materials.
The condition of submitting original
Due to stringent conditions, exporters ACCD should be clarified. The word
face difficulty in claiming export “copy” should be clarified or replaced
rebates. In particular for goods with “attested copy”. Verification of
exported to Afghanistan, these these documents to be made by official
conditions include submission of Government to Government channels
original Afghan Custom Clearing and rebate claims, if any, to be settled
Documents (ACCDs) which is after verification.
practically impossible as after
implementation of computerized Further, automation of procedures
system the Afghan customs should be introduced to help in
department issues a single original curtailing the time period required for
computerized ACCD which is required refund processing.
for motorcycle registration in
Afghanistan. Resultantly, all export The verification process should not take
rebates are put on halt by Custom more than two months in any case
authorities. from the date of filing of the case.
process with clear
 omobile Manufacturing
registration of contracts involving FCY
Pakistan Regulation Act (FERA) guidelines required.
repatriation.
7 Various (SECP, Incorporation related Scattered laws and regulations Single authority to obtain all regulatory
MOI and CCP) matters requiring various approvals from many and other approvals with regards to
different regulatory bodies at a single incorporation of companies to save
time. time.

For example, CCP is involved in

obtaining pre-merger clearance. There
is an extensive set of requirements
plus a hefty fee for that (JV is classified
as a merger as per CCP). Then SECP is
involved in obtaining incorporation
certificate. Ministry of Interior is
involved in obtaining clearance of
foreign shareholders and foreign
directors. For issuance of shares we
need to obtain auditors certificate, file
all the relevant returns with SECP, get
stamp from FBR, then approval from
SBP. Each authority has its own set of
rules and requirements. It takes a lot
of time and efforts to get approvals
from each body separately. Moreover,
registration with FBR, SRB, PRA,
WEBOC, KCCI etc are separately
required.

To make things easier and promote

the ease of doing business, it is crucial
to have simplified processes and
involvement of a single body to get all
the required approvals. This will help
the businesses as centralized authority

SRO 977 & 978 of 2019
issued by Ministry of
Commerce for Suspension
trade with India.
Ministry of National Health,
Drug Regulatory Authority
8 FBR (Custom)
of Pakistan issued
clarification to allow
therapeutic goods / difficulties.
Products (Raw Material for
Trading Business.
Pharmaceutical Industries)
but not being allowed parts
for medical equipment.
Amendment in Custom Act.
1969 and Law through
Finance Act, 2019-20, the
penalties under section 156
9 FBR (Custom)
read with section 79 are
revised. (Significant
penalties are increased
under this amendment)
will be able to get all the necessary
approvals on submission of single set
of documents and in less time.
Our installed base in different Import of some Indian origin parts from
hospitals (Public / Private sectors) other countries for already installed
need to keep functional for which healthcare equipment (not Indian
different parts are required time to origin) at different hospitals need to
time but right now we are facing be allowed under clarification issued by
Ministry of Health.
As per amendment in rules, only 10
days relaxation are not good enough
Public Sector Hospitals are exempted
after filing of GD which need to be
if they import directly medical
increased at least one month,
equipment and its parts. As per
otherwise required documents should
contract we facilitate them for
be simplified like just undertaking from
clearance of consignment where some
hospital without endorsement from
documents required from hospital
Ministry of Health should be accepted
including undertaking endorsed by
by Custom authority and EIF
Ministry of Health and Electronic
requirement should be eliminated.
Import Form (EIF) which take at least
one month time.
 Implementation of section 170 and 171

ManufacturingAutomobile
under income tax ordinance 2001.
The law is clear that refund has to be
made within specific period of refund
claim being made. Unfortunately, it is
10 FBR Refund process Difficulties in Advance tax refund not being followed and huge backlog
has been created. The businesses are
suffering due to high cost of funds
involved. Excessive liquidity has also
been tied up.
Power Generation

14 NEPRA Delay in monthly FCC It takes too much time which results in NEPRA should approve FCC on or
approval financial loss before 1st working day.

CPPA (Central As per agreement, CPPA Liquidity/ Cash flows issues to the CPPA should follow FIFO based
15 Power does not follow the FIFO Company payments to IPPS.
Purchasing while making payments to
Agency) IPPS.
CPPA (Central Enforcement of Arbitration CPPA is not accepting LCIA awards and CPPA should accept arbitration awards
Power Awards it is using delaying tactics to avoid as per contract.
16 Purchasing enforcement.
Agency)

FBR Sales Tax Refund Sales Tax refund is pending since
2015-16 due to increase in S.T. rate on
furnace oil by Gop from 17% to 20%.
17 Total due amount for APL is Rs. 623
million. We are in follow up with FBR
authorities but no refund released yet.
It has huge financial cost.
18 FBR Income tax exemption Takes a minimum of 3-4 weeks but
certificate issuance often gets delayed even more.
No additional request for exemption
FBR should issue payment schedule for
pending sales tax refunds of power
sector. There should be an automated
sales tax refund mechanism.
Should be issued within 7 working days
at maximum.
FBR system should be able to handle
 can be filed once the certificate multiple requests simultaneously for
against previous request is issued or issuance of Income Tax Exemption
rejected. Certificate.

Notes:
1. In column (a), please provide the name of business e.g. “garments manufacturing”, “retail shop”, “ice cream shop”, etc.

2. In column (b), “Name of the regulatory Dept. / agency”: please provide the name of the government department e.g. income tax department,
labour department, PSQCA etc.

3. In column (c’), “Specific Regulatory requirement causing difficulty”; please mention the specific procedure/ document of the department e.g.
“obtaining exemption certificate from RTO”, “Obtaining certification from PSQCA for imported products” etc.

4. In column (d), please explain what difficulty is being experienced, e.g. “too much time taken”, “the fee/expense involved” etc.

5. In column (e), please provide proposals about how to change the regulatory requirement, e.g. in case of duplication/ redundancy.