Tax

Strategic Advocacy in Complex Tax and Fiscal Disputes

JuristiQ Chambers advises and represents taxpayers in high-value, complex, and precedent-setting tax disputes across Pakistan. Our practice focuses on contentious tax matters, combining deep knowledge of fiscal statutes with strong appellate and constitutional advocacy before tax authorities, appellate tribunals, High Courts, the Supreme Court of Pakistan and the Federal Constitutional Court.

We act for corporates, financial institutions, multinational groups, high-net-worth individuals, and regulated entities, particularly where tax disputes intersect with regulatory action, cross-border transactions, and constitutional rights.

Regulatory & Statutory Framework

Our tax practice spans disputes arising under Pakistan’s principal fiscal statutes, including:

• Income Tax Ordinance, 2001

• Sales Tax Act, 1990 and provincial sales tax laws

• Federal Excise Act, 2005

• Customs Act, 1969

• Finance Acts and annual tax amendments

We routinely engage with matters involving the Federal Board of Revenue (FBR) and provincial revenue authorities.

Income Tax Disputes

We advise and act in complex income tax matters, including:

• Tax audits and enforcement proceedings

• Disallowance of expenses and capital allowances

• Transfer pricing adjustments and related penalties

• Permanent establishment disputes involving non-residents

• Taxation of cross-border services, royalties, and dividends

• Double taxation treaty interpretation and relief

Our work frequently involves the interpretation of fiscal statutes, delegated legislation, and treaty obligations.

Indirect Taxation

JuristiQ Chambers represents clients in disputes relating to:

• Sales tax assessment, refunds, and zero-rating

• Input tax adjustments and disallowances

• Federal excise duty on services and goods

• Provincial sales tax on services (Sindh, Punjab, Islamabad Capital Territory)

• Classification, valuation, and place of supply disputes

Such matters often raise constitutional questions concerning federal–provincial fiscal competence.

Customs & International Trade Taxation

We act in disputes involving:

• Customs valuation and tariff classification

• Custom Duty & Regulatory Duty

• Import and export restrictions and exemptions

• Anti-dumping and countervailing duties

• Penalties, confiscation, and enforcement actions

• Trade-related tax disputes before appellate forums

These matters frequently overlap with international trade, sanctions, and regulatory law.

Tax Appeals & Appellate Advocacy

JuristiQ Chambers has a strong appellate tax practice, regularly appearing before:

• Commissioner (Appeals)

• Appellate Tribunal Inland Revenue (ATIR)

• High Courts under constitutional jurisdiction

• Federal Constitutional Court and the Supreme Court of Pakistan in fiscal appeals

We are particularly engaged in questions of law, statutory interpretation, and challenges to retrospective taxation.

Constitutional & Public Law Challenges

We advise and litigate constitutional challenges involving:

• Ultra vires taxation and delegated legislation

• Retrospective and discriminatory tax measures

• Violation of fundamental rights under Articles 4, 9, 18, 23, and 25

• Federal–provincial tax competence disputes

• Recovery and coercive enforcement actions

Islamabad serves as a key forum for constitutional tax litigation involving federal authorities.

Penalties, Prosecution & Enforcement

We represent clients in contentious matters involving:

• Tax penalties and default surcharges

• Criminal prosecution under fiscal statutes

• Attachment of bank accounts and properties

• Stay and suspension of recovery proceedings

Our approach balances procedural safeguards, statutory defenses, and strategic relief.

Cross-Border & Corporate Tax Disputes

We regularly advise on disputes arising from:

• Cross-border corporate structures

• Withholding tax obligations

• Treaty-based claims and relief mechanisms

• Tax aspects of mergers, acquisitions, and restructuring

• Interaction between tax, corporate, and regulatory regimes

This work often overlaps with corporate, banking, and international arbitration matters.

Our Approach

Tax disputes demand precision, foresight, and strategic advocacy. JuristiQ Chambers offers:

• Tribunal-ready and appellate-focused representation

• Integrated tax and constitutional strategy

• Commercially aligned dispute resolution

• Coordination with accounting, valuation, and forensic experts

Our objective is to contain fiscal exposure, manage regulatory risk, and secure legally sustainable outcomes.

Tax Expertise

Income Tax · Sales Tax · Federal Excise · Customs & Trade Duties · Transfer Pricing · Constitutional Tax Litigation · Appellate Advocacy

Related Expertise

Banking & Finance · Corporate & Securities · International Trade · Public & Regulatory Law