June 7, 2024

Revenue Commission Proposes Reforms to Combat Real Estate Tax Evasion

real estate taxes on Pakistani Real estate

The Revenue Commission has recently proposed a series of reforms aimed at tackling tax evasion in Pakistan’s real estate sector. These recommendations, presented by the Reform and Revenue Mobilisation Commission (RRMC) under the leadership of Ashfaq Tola, are designed to increase transparency, enforce tax laws more effectively, and expand the tax base. At Makani Marketing, we believe it is crucial to keep our clients and stakeholders informed about these potential changes and their implications for the real estate market.

Key Proposals from the Revenue Commission

Mandatory Tax Registration for Property Transactions

One of the central recommendations is to make tax registration mandatory for both buyers and sellers of properties. This move aims to ensure that all property transactions are documented and traceable, thereby reducing the scope for tax evasion. By linking property transactions to tax registrations, the government can better monitor and regulate the real estate market.

Linking Capital Gains Tax Exemption to Asset Disclosure

The Commission proposes that the exemption from capital gains tax should be contingent upon the disclosure of assets at the time of purchase. This means that property owners must declare their properties in their wealth statements during the acquisition year and continue to do so until the property is disposed of. The exemption would be available once every three years, aligning with the intent to promote transparency and accountability in property ownership.

Tackling Benami Properties

Benami properties, or properties held in the name of another person to avoid taxes, are a significant issue in Pakistan’s real estate sector. The Commission recommends taxing these properties as soon as they are discovered, without any time limit. This proposal includes amending Section 111 of the Income Tax Ordinance to tax all undisclosed benami assets in the year they are identified. By doing so, the government aims to discourage the practice of hiding assets and expand the tax base.

Enforcing Compulsory National Tax Numbers (NTNs)

The report also suggests issuing compulsory National Tax Numbers (NTNs) to non-filers for specific transactions. This measure is intended to bring more individuals into the tax net and ensure that all significant financial activities are reported and taxed appropriately. The Federal Board of Revenue (FBR) is expected to support these recommendations, particularly those related to capital gains tax exemptions.

Addressing Under-Reporting and Expanding the Tax Base

The Tola Commission report highlights significant under-reporting of income and property values in Pakistan. Many taxpayers do not pay taxes according to their returns, leading to substantial revenue losses for the government. By implementing the proposed reforms, the Commission aims to enforce tax laws more rigorously and expand the tax base. This would help the FBR achieve its tax collection targets for the upcoming fiscal year.

Implications for Real Estate Investors

For real estate investors, these proposed reforms could lead to several significant changes:

  1. Increased Transparency: Mandatory tax registration for property transactions and linking capital gains tax exemptions to asset disclosure will enhance transparency in the real estate market. Investors will need to ensure that their transactions are fully documented and compliant with tax laws.
  2. Potential Tax Liabilities: Investors holding benami properties or under-reporting their assets may face increased scrutiny and potential tax liabilities. It is crucial for investors to review their portfolios and ensure all assets are properly declared.
  3. Market Dynamics: The proposed reforms could impact property prices and market dynamics. Increased transparency and enforcement may lead to a more stable and predictable market, but it could also result in short-term adjustments as the market adapts to the new regulations.

Makani Marketing’s Role

At Makani Marketing, we are committed to helping our clients navigate these changes and make informed investment decisions. Here’s how we can assist:

  1. Regulatory Guidance: Our team of experts provides comprehensive guidance on regulatory changes and their implications for real estate investments. We keep our clients updated on the latest developments and help them stay compliant with tax laws.
  2. Investment Advisory: We offer personalized investment advisory services to help clients optimize their portfolios in light of the proposed reforms. Our advisors work closely with clients to identify opportunities and mitigate risks.
  3. Property Management: For clients looking to maintain and manage their properties, we provide end-to-end property management services. From ensuring compliance with tax regulations to handling day-to-day management tasks, we take care of all aspects of property management.




The Revenue Commission’s proposed reforms represent a significant step towards combating tax evasion in Pakistan’s real estate sector. By enforcing mandatory tax registration, linking capital gains tax exemptions to asset disclosure, and addressing the issue of benami properties, these measures aim to enhance transparency, expand the tax base, and increase government revenue.

At Makani Marketing, we are dedicated to supporting our clients through these changes and helping them achieve their investment goals. Stay tuned for further updates and insights as we continue to monitor the implementation and impact of these proposed reforms on the real estate market.

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