How much advance income tax is collected at import under section 148 in tax year 2027, and is it higher if I am not on the Active Taxpayers List?

What does the law say?

Section 148(1) of the Income Tax Ordinance, 2001 requires the Collector of Customs to collect advance tax from every importer “on the value of the goods at the rate specified in Part II of the First Schedule”, for goods classified in Parts I to III of the Twelfth Schedule. Section 148(5) says it is collected in the same manner and at the same time as customs duty, or, for duty-free goods, at the time duty would have been payable.

The rate therefore depends on two things: where your goods sit in the Twelfth Schedule, and what kind of importer you are.

What are the rates for tax year 2027?

Part II of the First Schedule, as amended to 30 June 2026, sets these rates. Each is a percentage “of the import value as increased by customs-duty, sales tax and federal excise duty”.

Goods	Rate	Rate for a commercial importer
Part I of the Twelfth Schedule	1%	1% (no separate rate)
Part II of the Twelfth Schedule	2%	3.5%
Part III of the Twelfth Schedule	5.5%	6%

Part III is a catch-all: “Goods not specifically mentioned in Part I or II”. Part I includes items such as potatoes, tomatoes, onions, coal, natural gas, urea, potassic fertilisers, cotton, gold and a long list of machinery headings in Chapter 84. Part II lists many industrial inputs and parts by PCT code.

A proviso to the table then sets special rates:

Case	Rate
Manufacturers covered by the rescinded S.R.O. 1125(I)/2011, as it stood on 28 June 2019, importing items covered by it	1%
Finished pharmaceutical products not otherwise manufactured in Pakistan, as certified by the Drug Regulatory Authority of Pakistan	4%
CKD kits of electric vehicles: small cars or SUVs with 50 kwh battery or below, and LCVs with 150 kwh battery or below	1%

Mobile phones are taxed differently: a further proviso sets fixed rupee amounts per phone according to C&F value in US dollars, with separate columns for CBU and CKD/SKD phones. That table is covered on its own page.

What value is the rate applied to?

Section 148(9) defines “value of goods” three ways:

• (a) for goods taxed at retail price under the Third Schedule of the Sales Tax Act, the retail price increased by sales tax payable on the import and taxable supply;
• (b) for other goods, the customs value “as if the goods were subject to ad valorem duty increased by the custom-duty, federal excise duty and sales tax, if any, payable in respect of the import of the goods”;
• (c) where the Board has notified a minimum value under section 148(6A), that minimum value, increased in the same way.

Is it higher if I am not on the Active Taxpayers List?

Yes. Section 100BA(1) says that for a person not on the active taxpayers’ list, or a person on it who has not filed the return by the due date, the collection of advance tax “shall be determined in accordance with the rules in the Tenth Schedule”.

Rule 1 of the Tenth Schedule then says the rate of tax to be collected from such a person “shall be increased by hundred percent of the rate specified in this Ordinance”. Rule 10 lists the specific taxes the Schedule does not apply to, such as tax deducted from salary and tax on export proceeds. Tax collected under section 148 is not on that list, so the increase applies at import.

Goods and importer	ATL rate	Rate if not on the ATL
Part I	1%	2%
Part II, other importer	2%	4%
Part II, commercial importer	3.5%	7%
Part III, other importer	5.5%	11%
Part III, commercial importer	6%	12%

Worked example (illustrative figures)

Sana imports a consignment of Part III goods into Lahore dry port for resale. The customs value increased by customs duty and sales tax is Rs. 5,000,000.

1. She is a commercial importer, so Part II of the First Schedule gives 6%.
2. On the ATL: Rs. 5,000,000 x 6% = Rs. 300,000.
3. Not on the ATL: rule 1 adds 100% of 6%, so 12%. Rs. 5,000,000 x 12% = Rs. 600,000.
4. The cost of not being on the list, on this one consignment: Rs. 600,000 - Rs. 300,000 = Rs. 300,000.

If the same goods fell in Part II and she imported them as a commercial importer, the ATL figure would be Rs. 5,000,000 x 3.5% = Rs. 175,000, and the non-ATL figure Rs. 350,000.

What if the extra tax was collected and I file later?

The Tenth Schedule has its own procedure. Rule 3 lets the Commissioner make a provisional assessment where tax was collected under rule 1 and the person does not file by the due date. Rule 4(3) says that where returns are filed, the tax collected under rule 1 “shall be adjustable against the tax payable in the return filed for the relevant tax year”. How that interacts with the minimum tax rule in section 148(7) for a commercial importer is not spelled out in the Schedule.

Common mistakes

• Applying the rate to the invoice value. The base is the value after customs duty and sales tax are added, under section 148(9).
• Assuming the non-ATL increase is 2% flat. It is 100% of whatever rate applies, so 6% becomes 12%.
• Assuming Part III means rare goods. Part III is everything not listed in Parts I and II, so many consumer and trade goods land there.

What to check in the official text

Read Part II of the First Schedule and the Twelfth Schedule in the official PDF, since the site copy of the Ordinance leaves out schedules. Check the PCT code of your goods against Parts I and II. Check for Board notifications under the provisos to section 148(1), and any minimum value notified under section 148(6A); those notifications are outside this corpus.