Can I buy property, a car or shares in Pakistan without being a filer now that section 114C restricts ineligible persons?

The Finance Act, 2025 added section 114C to the Income Tax Ordinance, 2001. It lets banks, registrars, car makers and brokers refuse large transactions by people who have not shown their resources to FBR. Overseas Pakistanis often read about it and assume it blocks them too. The section has its own carve-out for non-residents, with one exception. This page follows the Ordinance as amended to 30 June 2026.

What does section 114C restrict?

Section 114C(1) sets four restrictions, each tied to a threshold in the Fifteenth Schedule:

Clause	Transaction	Fifteenth Schedule threshold	Applies to non-residents?
(a)	Booking, purchase or registration of a motor vehicle	Invoice value (or value assessed by Customs for an import), inclusive of all taxes, exceeding Rs. 7 million	No
(b)	Registering, recording or attesting transfer of immovable property	Fair market value exceeding Rs. 100 million	No
(c)	Opening or maintaining an account for securities, mutual fund units or similar investment	Acquisition cost exceeding Rs. 50 million of new investment in a financial year, excluding reinvestment	No
(d)	Cash withdrawal from bank accounts	Annual cash withdrawal of Rs. 100 million in all bank accounts held by an individual	Yes

Clauses (a) to (c) are aimed at an “ineligible person”. Section 114C(4) defines an eligible person as someone who filed a return for the previous tax year with sufficient resources in the wealth statement, or who filed a sources of investment and expenditure statement for the particular transaction. For an individual, eligibility extends to immediate family members: parents, spouse and dependent children.

Clause (d) is worded differently. It says “a banking company shall not allow cash withdrawal from any of the bank account of any person, exceeding the threshold”. The Fifteenth Schedule’s opening words say the thresholds are “to be applied in respect of ineligible persons”. The text does not reconcile those two wordings.

How does the non-resident exemption work?

Section 114C(2) says: “The provisions of sub-section (1), shall not apply on transactions made by a non-resident person or a public company except that mentioned in clause (d) of sub-section (1).” A non-resident person can therefore buy a car, register a property or invest in securities above the thresholds without being an eligible person. The only restriction left in place is the cash withdrawal limit.

The exemption turns on being a non-resident person, not on holding a NICOP or POC or on living abroad in a general sense. Section 81(2) says a person is non-resident for a tax year if the person is not a resident person for that year. Section 82 makes an individual resident on several tests, including presence in Pakistan for 183 days or more in the tax year. It also makes a citizen of Pakistan resident if the citizen “is not present in any other country for more than one hundred and eighty-two days during the tax year or who is not a resident taxpayer of any other country”. A Pakistani citizen who moves between countries without settling in one for more than 182 days, and who is not a resident taxpayer anywhere else, can be resident in Pakistan under that clause.

Is section 114C in force yet?

Section 114C(5) says the restrictions “shall come into force on such date as the Federal Government may, by notification in official Gazette, appoint”, with any reductions or increases in the thresholds it thinks appropriate. This corpus does not include such a notification. Check whether one has been issued, and whether it changed the thresholds, before relying on the figures above.

Worked example (illustrative figures)

Kamran works in Manchester. In tax year 2027 he spends 40 days in Pakistan, lives the rest of the year in the United Kingdom and is a resident taxpayer there, so under section 82 he is not resident in Pakistan for that year. He does not file Pakistani returns.

1. He buys a house in DHA Lahore with a fair market value of Rs. 120,000,000. That is above the Rs. 100 million threshold in clause (b), but section 114C(2) disapplies clause (b) for a non-resident. The registrar is not barred by section 114C from processing it.
2. He books a car with an invoice value of Rs. 9,000,000, above the Rs. 7 million threshold in clause (a). Section 114C(2) disapplies that clause too.
3. His brother Adnan lives in Lahore, is resident and did not file last year. Adnan wanting the same car would be an ineligible person under clause (a) unless he or an immediate family member he can rely on is eligible. Kamran is a brother, not a parent, spouse or dependent child.

Section 114C(2) removes the 114C bar. It does not remove other taxes on the same transactions. Advance tax on the property purchase is a separate matter, and clause (111AC) of Part IV of the Second Schedule keeps the non-filer increase away from a non-resident POC or NICOP holder on those property transactions.

Common mistakes

• Assuming a NICOP is enough. Section 114C(2) uses the words “non-resident person”. A NICOP holder who is resident for the year under section 82 is not covered.
• Assuming the exemption covers cash. Section 114C(2) keeps clause (d), the cash withdrawal limit, for non-residents.
• Treating the thresholds as final. Section 114C(5) allows the Federal Government to change them in the commencement notification.
• Confusing 114C with the non-filer tax rates. Section 114C is about whether a transaction can be processed. The higher advance tax rates for people off the active taxpayers’ list come from a different part of the Ordinance.

What to check in the official text

Read section 114C(1), (2), (4) and (5), the Fifteenth Schedule, sections 81 and 82, and clause (111AC) of Part IV of the Second Schedule. The commencement notification under section 114C(5), and any rules on the sources of investment and expenditure statement, are outside this corpus.