Is the profit on my Roshan Digital Account or NRVA deposit taxable in Pakistan?

Profit on an account opened by a non-resident under a State Bank of Pakistan scheme is, in most cases, exempt from income tax under the Second Schedule to the Income Tax Ordinance, 2001. The exemption depends on the type of account and, for rupee accounts, on where the money came from. This page reads the Ordinance as amended to 30 June 2026, so it describes tax year 2027 (1 July 2026 to 30 June 2027).

What does the law say?

Two clauses in Part I of the Second Schedule do the work.

Clause (78) exempts profit on debt derived from foreign currency accounts held with authorised banks in Pakistan, or certificates of investment issued by investment banks, under any foreign currency account scheme introduced by the State Bank of Pakistan. The exemption is for “non-resident individuals, non-resident association of persons and non-resident companies”.

Clause (79) exempts profit on debt from a rupee account with a scheduled bank held by a person maintaining a Non-Resident Pakistani Rupee Value Account (NRVA) or Non-Resident Business Value Account (NRBVA) under the State Bank scheme. It has one condition: the deposits must be “made exclusively from foreign exchange remitted into the said account”.

The Finance Act, 2026 rewrote clause (79). The earlier text limited it to a non-resident individual holding a POC, NICOP or CNIC. The current text refers to the account holder and the account type instead.

The Ordinance does not use the name “Roshan Digital Account”. It describes accounts by State Bank scheme. Whether a given account is an FCVA, NRVA or NRBVA is a banking question outside this corpus.

What happens if the exemption does not apply?

For a non-resident, profit on debt paid by a bank moves out of section 151. Section 151(2) says section 151 does not apply to profit on debt that is subject to section 152(2). Section 152(2) requires every person paying an amount to a non-resident to deduct tax at the rate in Division II of Part III of the First Schedule, which is 20% of the gross amount.

Clause (5A) of Part II of the Second Schedule reduces that. For profit on debt payable to a non-resident with no permanent establishment in Pakistan, “other than those covered under clauses (78) and (79)”, the rate is 10% of the gross amount.

The proviso to clause (5A) makes the deduction a final tax only for investments in debt instruments and government securities made through a Special Rupee Convertible Account. It does not say the same for an NRVA or FCVA.

For comparison, a resident’s ordinary bank deposit falls under section 151(1)(b). Division IA of Part III of the First Schedule sets 20% of the profit paid by a banking company on an account or deposit.

Does the non-filer rate apply?

No. Clause (111AB) of Part IV of the Second Schedule says the special provisions for persons not on the Active Taxpayers List, including rule 1 of the Tenth Schedule, do not apply to a Foreign Currency Value Account (FCVA), Foreign Currency Business Value Account (FCBVA), NRVA or NRBVA with authorised banks under State Bank foreign exchange regulations. Rule 1 of the Tenth Schedule is the rule that increases withholding rates by one hundred percent for persons not on the Active Taxpayers List. So the account holder’s filing status does not raise the deduction on these accounts.

Worked example (illustrative figures)

Two brothers in Dubai each hold an NRVA with a bank in Karachi. Each earns Rs. 500,000 of profit in tax year 2027.

Asad funded his account only with remittances from his UAE salary.

1. Clause (79) condition met: deposits came exclusively from remitted foreign exchange.
2. Profit exempt. Tax deducted: Rs. 0.

Kamran remitted money too, but also transferred Rs. 1,000,000 into the NRVA from a rupee account in Lahore.

1. Clause (79) condition not met, because not every deposit was remitted foreign exchange.
2. He is non-resident with no permanent establishment, so section 152(2) applies at the clause (5A) rate of 10%.
3. Tax deducted: 500,000 x 10% = Rs. 50,000.
4. Clause (111AB) means that figure is not doubled even though he is not on the Active Taxpayers List.

What if I move back to Pakistan?

Clause (78) is limited to non-residents. Clause (79) is tied to maintaining an NRVA or NRBVA under the State Bank scheme. The Ordinance does not say what happens to profit accrued in the year your residence status changes. Whether you are resident is decided separately for each tax year, which this page does not cover.

Common mistakes

• Assuming every NRVA is automatically exempt. Clause (79) has a funding condition. One local rupee deposit can defeat it.
• Applying the resident 20% bank rate to a non-resident. Section 151(2) sends a non-resident’s profit to section 152(2), and clause (5A) sets 10%.
• Expecting the Tenth Schedule increase. Clause (111AB) switches it off for these accounts.

What to check in the official text

Read clauses (78) and (79) of Part I, clause (5A) of Part II and clause (111AB) of Part IV of the Second Schedule, and section 152 in full, including sub-section (3). The State Bank of Pakistan scheme documents that define the FCVA, NRVA and NRBVA, and the terms of any Roshan Digital product, are outside this corpus.