488

The rate of tax to be deducted 1[on return on investment in sukuks from a

sukuk holder] shall be—

(a) 2[25]% in case the sukuk-holder is a company;

(b) 12.5% in case the sukuk-holder is an individual or an
association of person, if the return on investment is more than
one million;
(c) 10% in case the sukuk-holder is an individual and an
association of person, if the return on investment is less than
one million; and]
3[ ]
4[Division II
Payments to non-residents
(1) The rate of tax to be deducted from a payment referred to in sub-section
(1A) of section 152 shall be 5[7% of the gross amount payable 6[ ] s].
7[(1A)
The rate of tax to be deducted from payments referred to in sub-
section (1AA) of section 152, shall be 5% of the gross amount paid.]

(2) The rate of tax to be deducted under sub-section (2) of section 152 shall
be 8[20]% of the gross amount paid.]
9[(3) The rate of tax to be deducted under sub-section (1AAA) of

section152, shall be 10% of the gross amount paid.]

1
The expression “under section 150A” substituted by the Finance Act, 2021.
2
The figure “15” substituted through Finance Act, 2020 dated 30th June 2020.
3
In Division IB, paragraph(d)omitted through Finance Act, omitted paragraph read as follow:
“(d) 17.5% in case the sukuk-holder is a non-filer”
4
Division-II substituted by the Finance Act, 2006. The substituted “Division-II” read as follows:
“Division II
Payments to non-residents
The rate of tax to be deducted under sub-section (2) of section 152 shall be 30% of the gross amount
paid.”
5
The expression “6% of the gross amount payable” substituted by the Finance Act, 2016.
6
The words “in case a person is a filer 13% in case the person is a non-filer” omitted through Finance
Act, 2019.
7
Inserted by the Finance Act, 2008.
8
The figure “30” substituted by the Finance Act, 2010.
9
Added by the Finance Act, 2012.
 489

1[(3A)The rate of tax to be deducted under 2[sub-sections (1D) and (1DA)]

of section 152 shall be 10% of the amount of capital gain.]
3[(4)
The rate of tax to be deducted from a payment referred to in clause (a)
of sub-section (2A) of section 152 shall be—

(i) in case of a company, 4[5%] of the gross amount payable 5[ ] ; and

(ii) in any other case, 6[5.5%] of the gross amount payable 7[ ]

8[(5) The rate of tax to be deducted from a payment referred to in clause

(b) of sub-section (2A) of section 152 shall be —
9[(i) 10[4%] of the gross amount payable, in the cases of transport
services, freight forwarding services, air cargo services, courier
services, manpower outsourcing services, hotel services,
security guard services, software development services, IT
services and IT enabled services as defined in 11[section 2],
tracking services, advertising services (other than by print or
electronic media), share registrar services, engineering
services, car rental services, building maintenance services,
services rendered of Pakistan Stock Exchange Limited and
Pakistan Mercantile Exchange Limited inspection and
certification, testing and training services 12[, oilfield services];]

1
New clause (3A) inserted through Tax Law (Second Amendment) Ordinance, 2019 dated 26 th
December, 2019
2
The expression “sub-section (1D)” substituted by the Finance Act, 2021. Earlier this substitution was
made through Tax Laws (Amendment) Ordinance, 2021.
3
Paragraph (4) substituted by the Finance Act, 2015. The substituted paragraph read as follows:-
“(4) The rate of tax to be deducted from a payment referred to in clause (a) of sub-section
(2A) of section 152 shall be 3.5% of the gross amount payable.”
4
The expression “4%” substituted by Finance Act, 2023.
5
The words “, if the company is a filer, 7% if the company is a non-filer” omitted through Finance Act,
2019.
6
The expression “4.5%” substituted by Finance Act, 2023.
7 The words “, if the person is a filer and 7.75% if the person is a non-filer.” Omitted through Finance

Act, 2019
8
Added by the Finance Act, 2012.
9
Sub para (i) substituted through Finance Act, 2020 dated 30th June, 2020 the substituted para read
as follows: “(i) in the case of transport services, two per cent of the gross amount payable; or”
10
The expression “3%” substituted by Finance Act, 2023.
11
The expression “clause(133) of Part I of the Second Schedule” substituted by the Finance Act,
2021.
12
Inserted by the Finance Act, 2021.
 490

1[(ii) in cases other than 2[sub-paragraph (i)],—

(a) in case of a company, 3[9%] of the gross amount payable 4[ ];

and

(b) in any other case, 5[11%] of the gross amount payable, 6[ ];]
7[(6)
The rate of tax to be deducted from a payment referred to in clause
(c) of sub-section (2A) of section 152 shall be,—

(i) 10% of the gross amount payable in case of sportspersons;

8[(ii) 9[ ] 10[8%] of the gross amount payable 11[ ].]
12[ ]
Division III
Payments for Goods or Services

(1) The rate of tax to be deducted from a payment referred to in clause

(a) of sub-section (1) of section 153 shall be –

1
Sub-paragraph (ii) substituted by the Finance Act, 2015. Substituted sub-paragraph read as
follows:- “(ii) in any other case, six per cent of the gross amount payable.”
2
The expression ‘transport’ substituted through Finance Act, 2020
3
The expression “8%” substituted by Finance Act, 2023.
4
The words “, if the company is a filer and 14% if the company is a non-filer” omitted through Finance Act,
2019.
5
The expression “10%” substituted by Finance Act, 2023.
6
The words “, if the person is a filer and 17.5% if the person is a non-filer” substituted through
Finance Act, 2019.
7
paragraph (6) substituted by the Finance Act, 2015. Substituted paragraph read as follows:-
“(6) The rate of tax to be deducted from a payment referred to in clause (c) of sub-section
(2A) of section 152 shall be six per cent of the gross amount payable.”
8
Sub-paragraph (ii) substituted by the Finance Act, 2016. Substituted sub-paragraph read as follows:-
“(ii) in case of a company, 7% of the gross amount payable, if the company is a filer and 10%
if the company is a non-filer;”
9
The words “in case a person is a filer,” omitted through Finance Act, 2019.
10
The expression “7%” substituted by Finance Act, 2023.
11
The words “and 13 % if the person is a non-filer ,” omitted through Finance Act, 2019
12
Sub-paragraph (iii) omitted by the Finance Act, 2016. Omitted sub-paragraph read as follows:-
(iii) in any other case, 7.5% of the gross amount payable, if the person is a filer and 10% if the
person is a non-filer.”]