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Kamal Tax Consultants

What buying or selling property costs a non-filer

A non-filer pays several times the filer rate of advance tax on a property transfer, so on a transaction of any size the extra tax is far larger than the cost of filing a return and getting onto the Active Taxpayers List first.

Ain Uddin

Income Tax Practitioner (ITP)

Last reviewed

6 September 2026

Property is where being off the Active Taxpayers List costs the most money in Pakistan, and it is the one place where the arithmetic is impossible to argue with.

The two sections that apply

Advance tax on a property transfer is collected under two sections, and which one applies depends on which side of the deal you are on.

Section 236K is collected from the buyer at the time the transfer is registered. Section 236C is collected from the seller on the same occasion.

Both are advance income tax, not a separate transaction levy, which means both are adjustable against your annual liability when you file a return. If you never file, neither is ever adjusted, and the money is simply gone.

Three rates, not two

Most people know there is a filer rate and a non-filer rate. There is also a middle rate for a late filer, meaning someone who did file but after the due date.

The gap between the filer and non-filer rate widens as the value rises. On a modest transaction the difference is uncomfortable. On a larger one it is the difference between the deal working and not working.

Our property tax calculator shows the exact figures for any value, and shows the extra amount your status is costing you.

The status that counts is the status on the day

The registrar checks the Active Taxpayers List on the day the transfer is presented. Your status on that day is what determines the rate.

This has a practical consequence. Filing a return the week before a transfer does not help you, because the list only republishes on Mondays. Allow at least ten days between filing and the transfer date, and confirm your status by SMS to 9966 before you go to the registry.

Becoming a filer first is almost always cheaper

Getting onto the list means registering, filing a return for the last completed tax year, and paying the tax due on it plus a surcharge if the return is late.

Set that total against the extra advance tax a non-filer pays on the transfer. On a transaction of any real size the comparison is not close, and it repeats on every future transaction as well.

What the department sees

Every registered property transfer is reported to the FBR. A purchase by someone with no filing history produces a notice, usually under section 111, asking how the purchase was funded.

Answering that notice needs a documented source: declared income across earlier years, a documented sale of another asset, an inheritance, or a remittance through banking channels. Buyers who have never filed have none of that on record, which is why a plot bought quietly becomes an assessment three years later.

If you are selling

Sellers face the same list check and the same three-rate structure under section 236C. Sellers also need to consider capital gains on the disposal, which depends on the holding period, and that is a separate computation from the advance tax collected at transfer.

About the author

Ain Uddin leads the practice and personally reviews every assessment, notice reply and appeal that leaves this office. As a licensed Income Tax Practitioner he can represent you before the FBR, which an unlicensed agent cannot.

Kamal Tax Consultants, Quetta. 0335 1358871.

Questions on this

Can a non-filer buy property in Pakistan?
A non-filer can buy but pays a much higher rate of advance tax under section 236K, and restrictions apply to certain transactions above prescribed values.
How quickly can I become a filer before a property transfer?
Registration and filing can be completed in a few days, but the Active Taxpayers List updates weekly, so allow at least ten days before the transfer date.
Is advance tax on property refundable?
It is adjustable against your annual tax liability when you file a return, and any excess can be claimed as a refund. Without filing, none of it comes back.

Rather we handled it?

Reading it is one thing. Filing it correctly, on time, and defending it if the FBR asks questions is what we do every day.

We call or message on WhatsApp. Your number is never shared.

Or call 0335 1358871 directly. Monday to Saturday, 11:00 am to 7:00 pm (PKT).