|#||Business Activity||PSIC Class||Regulatory Department||Regulatory Requirements Causing Difficulty||Nature of Difficulty||Proposal for Simplification||Proposal Category||Proposing Organization||Status|
|1||Technical Testing & Analysis||7,120||Federal Board of Revenue||Indirect Taxes||Withholding Tax & Minimum Tax on Revenue deduction at source u/s 153 1(b) causing heavy cost to the industry||Service industry is taxed on revenue and not on corporate profits (EBIT). The %age of minimum tax on revenue is 3% and it is difficult to absorb this cost from the minimal margins under services business. However, other sectors are being tax on corporate profits @ 29% which is contrary to the service sector. Therefore, clause of minimum taxation on revenue should be abolished.||Policy||ICCI|
|2||Technical Testing & Analysis||7,120||Federal Board of Revenue||Tax Refunds||Pending tax refunds in FBR are causing adverse effect in cash flow management of the industry. Service sector pays heavy taxes in advance throughout the years (in shape of minimum tax) while determined tax at the end of the year is quite less than the paid amounts. Hence, cash is blocked up and new ventures and future business growth is affected due to shortage of working capital.||Govt. should advise FPR to release the pending tax refunds to the service sector organizations (without conducting tax audits) in order to alleviate the economic burden being faced by the industry. Secondly, till the time refunds are not released the concerned business entities must get the tax exception certificate as a matter of relief not to pay minimum tax @ 3% i.e. present rate) in advance.||Policy||ICCI|
|3||Technical Testing & Analysis||7,120||Federal Board of Revenue / Punjab Revenue Authority / Sindh revenue board / KPK revenue authority||15 days for submission of GST after issuance of invoice against services provided||In this case service provider pays the sales tax amount on behalf of customer in advance which seriously crate challenges in cash flow management.||Sales tax should be paid at the time of receipt of payment instead of by the recipient to the service / customer issuance of sales tax invoice. The payment time of sales tax should be at least 75 days after issuance of the sales tax invoice.||Policy||ICCI|
|4||Technical Testing & Analysis||7,120||Federal Board of Revenue / Punjab Revenue Authority / Sindh revenue board / KPK revenue authority||Higher rates of imposing sales tax i.e. ICT @ 16%, PRA @ 16%, SRB 13%, KPK @ 15%||Higher rates of sales tax crate unnecessary burden on the customer side in terms of cash flows i.e. over and above impact on contract value.||The %age of sales tax on services shall be revised to a flat rate 5% overall. And this Sales Tax should be adjustable / admissible at the time of filing of monthly Sales Tax return instead of paying it in advance (under low margins and recovery challenges we have to pay advance sales tax in spite of the fact that payments are delayed from the client).||Policy||ICCI|
|5||Technical Testing & Analysis||7,120||Punjab Food Authority||Acknowledgement of expertise||PFA is creating its own market even without having expertise in all food related sectors||PFA should come up with collaboration with bodies who have international exposure.||Policy||ICCI|
|6||Technical Testing & Analysis||7,120||Oil & Gas Regulatory Authority (OGRA)||Registration of 3rd party inspection companies with OGRA. A company has to wait 3 years to reappear for registration.||This process is extremely tedious as it is highly bureaucratic and requires a lot of red tape. Companies are selected on basis of nepotism, causing only the preferred companies to stay in the pool. The rest are rejected and have to wait 3 years to try to be registered||We suggest that registration process should be a regular process throughout the year and whenever a 3rd party inspection company want to register, OGRA should accept their application and process for registration / prequalification any time. There should strict transparency checks which ensure that process is free & fair for all, without any bias or prejudice towards any company.||Policy||ICCI|
|7||Manufacture of Medical and Dental Instruments and Supplies||3,250||Drug Regulatory Authority of Pakistan (Drug Regulatory Authority of Pakistan)||1. Too many documents required for registering company for import of a non drug item. 2. Wrapping paper sheets, paper Flat rolls and paper bags used to wrap instruments for sterilization in CSSD machines and other non-drug items must be registered as “Medical Devices”. 3. High charges / fee for company registration and then for product registration. 4. Too many requirement for approval of premises used for storage of goods||1. 24 no of SOPs, many checklists and other forms 2. A company already has Drug License and registered with DHO, Ministry of health requires another registration with Drap for import of goods. 3. Fee of Rs. 25000 for registration 4. Non-Drug items registration in the name of Medical Devices||1) No of SOPs & other Docs to be reduced to 5 only 2) No registration for companies who already obtained Drug license and Registered with DHO, Ministry of health. 3) No compulsory registration for wrapping sheets & Flat rolls and other items which do not touch the patient body. 4) fee to be reduced to Rs. 10000/- for company registration and Rs. 500 for each item registration. 5) No requirement of Generator, UPS / Air conditioner, Cold storage, etc for the Storage of Non-Drug, Non-Surgical items .||Administrative||ICCI|
|8||Support activities for petroleum and natural gas extraction||910||DGPC / Explosive department / Ministry of Industries||1- Currently importing and using of explosives for Oil and gas industry requires very lengthy process and too much paper work in every department. 2- First the Oil company like DGDC or PPL gives letter to DGPC for directing explosive department to issue license, DPGC needs many documents for each license then DGPC writes to explosives department who also requires many papers and then explosive department writes to ministry industry who then sends it to Wash Nobel. 3- Wah Nobel writes back to Ministry of Industry and based on Wah Nobel approval ministry writes NOC to Explosive department. After all this procedure explosive department issues license which is only valid for one import and then explosive license for each district where well is being drilled or well are producing, every license fee is 500, 000 Rupees and also need all above steps.||Very time consuming, too much paper work and cost||It should be made simple like other countries. 1- Once contract is awarded by Oil Company, thy should write to DGPC for authorizing us to use explosive service for the whole duration of the contract not for 6 months. 2- DGPC should grant permission to service companies for import license for the whole duration of contract not for every import. 3- Explosive license should be applicable for all leases which are being drilled and produced by the Oil Company not every district needs requires new license.||Policy||ICCI|
|9||Support activities for petroleum and natural gas extraction||910||Explosive Department||Currently service company has to make his own bunker for storage, arrange his own transportation to the well site. We are not expert in this field and needs a lot of paper work to report every 15 days about each license usage. It is also not safe to have bunkers for each company in every part of the country. There are huge chances of leakage as its custody is in private hands.||Time consuming and security||Like other countries, explosives should be stored in paramilitary custody in their won bunkers and thy should be responsible for its custody and transportation to the well site and back to bunker. This will give government complete control over leakage of any explosives.||Policy||ICCI|
|10||Financial service activities, except insurance and pension funding||64||Directorate General of Immigration & Passports||Not able to get more than one year visa to Pakistan||Although the policy states that ‘Missions will give 5 years Multiple Business Visa within 24 hours to businessmen’, it is extremely difficult to get a visa for more than a year despite having good investments here in Pakistan and several consecutive yearly visas.||After having received 2 -3 consecutive yearly business visas, ne should automatically qualify for a 3 – 5 year multiple entry business visa.||Administrative||ICCI|
|Regulatory Department||Proposal Category||Proposing Organization|
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