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TAX NEWS APRIL 21, 2016



1.      Subsidisation of CWSP imports: US initiates anti-dumping duty probe

April 21, 2016

The country''s already depleting exports are set to receive a serious blow as the United States has imposed a 65 percent countervailing duty (CVD) on the imports of circular welded steel pipes (CWSP) from Pakistan, according to American authorities in Islamabad. The US Department of Commerce (DoC) also has initiated Antidumping Duty (AD) probe into the import of circular welded pipes (CWP) from Pakistan, Oman, Philippines and United Arab Emirates. "On April 4, 2016, the Department of Commerce... announced its affirmative preliminary determination in the countervailing duty (CVD) investigation," reads a fact sheet of DoC a spokesman of US Consulate Karachi, Brian Asmus, made available to Business Recorder.

The America''s protectionist move is going to make a multimillion dollar cut in the exports of Pakistan. With Ministry of Commerce having set, in the delayed Trade Policy in March, a $35 billion export target by 2018, the first nine months of current fiscal year, July-MarchFY16, saw the country''s exports shrinking 13 percent to $15.6 billion compared to $17.9 billion of FY15''s corresponding period.

US being the largest trade partner of Pakistan, the dollar-hungry Islamabad sold out 56,700 metric tons ($50.62mn) of the now-banned carbon-quality steel pipes to America during a three-year period: $23.79 million in 2012, $9.78 million in 2013 and $17.04 million in 2014. =

The probe came as a result of a petition filed on October 28 last year by Bull Moose Tube Company (MO), EXLTUBE (MO), Wheatland Tube (IL) and Western Tube & Conduit (CA) which accused the Government of Pakistan of having assigned a preliminary subsidy rate of 64.81 percent for the exporters and producers of CWP. \

In the petition, the filers have made Pakistan''s International Industries Limited (IIL) as a "mandatory respondent". "The preliminary subsidy rate is based on facts available and adverse inferences following Commerce''s preliminary determination that the mandatory respondent and the Government of Pakistan had not fully co-operated in the investigation," the DoC claimed. "All other exporters/producers in Pakistan have also been assigned a preliminary subsidy rate of 64.81 percent," it said.

Its positive preliminary findings would lead to DoC instruct the US Customs and Border Protection to "require cash deposits based on these preliminary rates" of 64.81 percent. The Pakistani products subject to this investigation are currently classifiable in Harmonised Tariff Schedule of the United States (HTSUS). In Pakistan, while the exporters use words like "allegedly" for DoC claiming Islamabad was subsidising the export of CWSP, officials related to the country''s trade appear less worried about the negative. Commerce Minister Khurram Dastgir Khan whereas was not available for comments, CEO Trade Development Authority of Pakistan (TDAP) S M Muneer appeared totally unaware of any such development. When apprised, he said "such probes are very common in the comity of world."

"They have all the right to protect their (steel) industry," TDAP chief told Business Recorder. In a stock filing on April 7, IIL informed its shareholders at Pakistan Stock Exchange about the US DoC having started AD and CVD investigations on the imports of CWSP from Pakistan.

"DoC... in order to protect its local industry imposed a CVD of 64.81 percent until the final determination," said Yasir Ali Quraishi, IIL''s company secretary. "Our future sales to the US market have stopped owing to such preliminary determination," he added. Assisted by the Government of Pakistan, his company, Yasir said, intended to continue contesting the preliminary determination and was hopeful, based on the merits of the case, that the said punitive measure would be overturned at the stage of final determination.

The US International Trade Commission (ITC) and DoC are due to make the final determination in the matter on August 16. "(Department of) Commerce is scheduled to announce its final determination in this investigation on August 16, 2016, unless the statutory deadline is extended," says the fact sheet.

It said if the DoC and ITC made an affirmative final determination that the imports of CWSP from Pakistan "materially injure, or threaten material injury to, the domestic industry, Commerce will issue a CVD order." "If either Commerce''s or the ITC''s final determination is negative, no CVD order will be issued," it said adding "The ITC is scheduled to make its final injury determination approximately 45 days after Commerce issues its final determination, if affirmative."

2.      ST, duty on all defence imports may be waived: Senate informed

April 21, 2016

The Senate was informed on Wednesday that sales tax and custom duty may be waived off on all defence imports, besides IBC for defence budget 2016-17 may be revised from Rs 860 billion to Rs 920 billion. A report of Senate Standing Committee on Defence that was presented in the house by its chairman Senator Mushahid Hussain Sayed said that a pay and pension commission should be constituted besides adopting one rank one pension formula for defence services.

It also recommended that power to waive off austerity measures of defence organisations may be delegated to secretary defence, adding 40 percent deduction from coalition support fund reimbursement by government may be discontinued. It also said that out of total $13 billion received through CSF from US since 9/11, 40% has gone to the civilian government. The current year being the last year in respect of CSF, it added, a balance amount of $200 million remains to be cleared by the US government.

The report also recommended to enhance the budgetary allocation to three armed forces according to threat perception, adding the budget allocation to all three armed forces should be related to threat perception which is markedly enhanced due to the current geo-political situation and Pakistan's strategic location in the area.

Referring to a recent meeting of "Pak-US Strategic Dialogue", it added, a proposal of establishing a border management fund to the tune of $100 million was discussed.

The defence ministry has put forward a proposal for the development of Federally Administrative Tribal Areas (FATA) to the tune of $8 billion spread over 5 to 8 years, it said, adding US government has agreed that a robust border management is essential for maintenance of peace on Pak-Afghan border and further negotiations on the matter will continue.

3.      Biggest-ever tax evasion case of builder unearthed

April 21, 2016

Directorate General of Intelligence and Investigation Inland Revenue (IR) has unearthed the biggest tax evasion case of a builder/developer in the history of Pakistan involving approximately tax liability of Rs 58.8 billion calculated on total tax concealment of Rs 117.6 billion. Sources told Business Recorder here on Wednesday that the Karachi based builder/developer, one of the biggest and powerful developers in the real estate sector, is allegedly involved in massive concealment of income.

The analysis of 4 banks' data, inspection of records and detailed scrutiny of data exposed concealment to the tune of Rs 117.6 billion. This is the biggest tax concealment case in the history of FBR within the real estate sector and recovery of the evaded amount may result in contribution of approximately Rs 58.8 billion in the national kitty. The directorate has detected total concealment of Rs 117.6 billion, tax Rs 29.4 billion @ 25 percent average. Penalty 100 percent of tax comes to Rs 29.4 billion. Total tax liability comes to approximately Rs 58.8 billion. The quantum of tax evasion is so high that only one mega case could result in sudden increase in revenue collection of the FBR.

FBR officials said that the credit definitely goes to Khawaja Tanveer Ahmad, a top officer of Inland Revenue Service, who is also Director General of Intelligence and Investigation Inland Revenue, who supervised/monitored and pleaded case despite immense pressure from powerful groups and lobbies. However, Karachi based courageous officials of the agency completed the investigation against this biggest builder/developer of Karachi.

Directorate General of I&I IR has taken a historic initiative to unearth massive concealment of income by an influential real estate developer of Karachi. Through analysis and investigation of records, preliminary data exposed concealment to the tune of billions by the said real estate developer. Such actions against big sectors have pointed towards the seriousness of the agency to assist the FBR in achievement of the assigned revenue collection targets for 2015-16.

Keeping in view sensitively of some big cases, the agency has completed the legal formalities of taking prior permission of high-ups and availability of irrefutable evidence for taking action against the units. For the first time in the history of FBR, the Directorate General of Intelligence and Investigation Inland Revenue has continued its investigations in real estate sector to ensure recovery of concealments involving billions of rupees. As a result of these actions, the Directorate General of Intelligence and Investigation IR has emerged as top investigative agency in detection of tax frauds in the country, sources maintained.

Details of the case revealed that the credible information was received by the Directorate of I&I-IR, Karachi, from field visit that the business activities of a proprietor of builders and developers of Karachi are not commensurable with his declared versions. Reportedly, the proprietor of builders and developers was executing more than one dozen construction projects under various titles. Each project was being executed under the umbrella of a separate AOP, with different partners and terms of conditions, to hide income and evade due taxes. In addition a significant number of investors have made investments in these projects and retrieval of such information would be useful in Broadening of Tax Base (BTB) activities.

Accordingly, action under section 175 of the Income Tax Ordinance, 2001 was carried out on the principal business place of the taxpayer located in Karachi, and the team resumed relevant record for further scrutiny, On the basis of information, relating to bank accounts, letters were written to the Mangers of relevant Bank / Branches for provision of bank information in respect of various bank accounts associated with taxpayer. Perusal of bank statements has endorsed the contention of the Directorate.

Realising the establishment of concealment, in his case, the taxpayer approached the High Court of Sindh, Karachi, and filed civil suit against the action taken by the department. The court has passed restraining order in the case on April 11, 2016 and directed that no further proceedings can be carried out in the case. The directorate will represent the case before the High Court of Sindh, sources added.

4.      LHC issues notice to President for setting aside FTO's order

April 21, 2016

Lahore High Court (LHC) has issued a notice to the President of Pakistan, who has set aside an order of the Federal Tax Ombudsman (FTO), which has directed the Federal Board of Revenue (FBR) to vacate order under Section 122 of the Income Tax Ordinance, 2001 and warned the assessing officer for levelling allegations without referring to any supporting evidence.

Sources told Business Recorder that LHC has admitted a constitutional petition against the President on the issue of acceptance of representation filed by the Federal Board of Revenue (FBR) under Section 32 of the Federal Tax Ombudsman Ordinance, 2000 against an order passed by the FTO.

It is learnt that petition was moved by a Gujranwala based taxpayer through Waheed Shahzad Butt, Advocate, challenging the acceptance of representation by the President of Pakistan against the order passed by FTO Chaudhry Abdur Rauf, stating that act of office of President is patently illegal. The order passed by office of President is un-constitutional and without lawful authority, hence, the same is liable to be declared unlawful and quashed.

Earlier, the FTO issued order to the FBR to direct the concerned Commissioner-IR to invoke revisionary jurisdiction under Section 122A of the Ordinance to vacate order passed under Section 124/122(1) of the Ordinance and dispose of the rectification application pending before the ACIR, the CIR concerned to warn the assessing officer for levelling allegation of deliberate fabrication of accounts by the chartered accountant/auditor in connivance with taxpayer without referring to any supporting evidence and all field formations to exercise regular supervisory oversight of work done by the assessing officers and ensure that prompt cognisance is taken of all whimsical and arbitrary actions.

Petitioner claimed that "It is the duty of office of President to dispense justice and functionaries representing office of President are supposed to uphold the dignity of law and respect command and orders of the Courts. On the other hand due to illegal acceptance of representation under section 32 of the FTO Ordinance, 2000, the process of law is being abused badly by the office of President, petition claimed.

The petitioner claimed that it appears some officials working in the Presidency are involved in unduly favouring revenue division employees, by admitting the illegal void representations, filed against the orders passed by the FTO. The act of officials representing of the Presidency is prima facie without lawful jurisdiction, President is requested to take action against those responsible for such illegal act, under his mandate and his commitment for Zero tolerance for corruption and unfair practices because it is the duty of state functionaries to dispense justice, the lawyer pleaded.

Petitioner further claimed that the office of President is involved in violation of provisions of Federal Tax Ombudsman Ordinance, 2000, Income Tax Ordinance, 2001 and Constitution of Islamic Republic of Pakistan, 1973, which is itself equivalent to maladministration and denial of justice. It seems that there is an intentional attempt to dump the office of the FTO who is providing real redressal of grievance to the aggrieved taxpayers of Pakistan against the patently illegal intervention by the Revenue Division employees, petitioner added.

 

 

 

5.      Export sectors: government urged to fulfil promise of zero rating

April 21, 2016

The government has gone back on its promise of zero rating for five export sectors, which will indeed prove most disastrous for the country's exports and economy, said Muhammad Jawed Bilwani, Chairman, Pakistan Apparel Forum on Wednesday.

He strongly articulated that it was very serious that the exports have declined further by 12.92% to $15.606 billion in the first nine months of the current fiscal year (July-March 2015-16) from $17.921 billion during the same period last year While the exports of our regional competitors have increased. Isn't it a great irony and dilemma that exports have decreased by Rs 239 billion which clearly proves the amount of foreign exchange earnings lost by our nation. Further Rs 239 would have been in circulation and would have resulted in earnings in tax revenue. The export target is $35 billion for the current fiscal year and with negative growth in exports, we are still 26% behind the target.

The decision not to grant zero rating to the five export sectors would be tantamount to crippling and ruining our exports and would indeed be suicidal because it has taken a lot of pains and troubles for the five zero rated export sectors to struggle to export against tough competition from regional competing countries with heavy odds against them such as huge amount of their piled up liquidity outstanding with the government in Sales Tax Refund Claims, Customs Rebate Claims and DLTL Claims and to crown this all, rising cost of inputs.

Bilwani stressed that it is imperative that the government of Mian Muhammad Nawaz Sharif - a business friendly government - keeps the promise and commitment made by none other than the Prime Minister of Pakistan, Mian Muhammad Nawaz Sharif himself to grant the most practical zero rating facility in Sales Tax to the five vital export sectors only because Zero Rating Facility extended in 2005 greatly helped in boosting exports.

Bilwani was dismayed by the fact that despite tall claims of release of held up Sales Tax Refund Claims of exporters only some payments of claims below Rs 5 million against those RPOs issued till August, 2015 were paid and that too, payments were made to a favoured few. For exporters with claims over Rs 5 million, initially they were promised payments in the form bonds and later payments in cheque but it is surprising, he said, that as yet no payments have been made to them despite the fact that RPOs against the same have been issued for 19 months.

He most earnestly appealed to the Prime Minister of Pakistan that the zero rating - "No Payment No Refund" system for exports should be implemented forthwith as per his commitment made with the exporters because collecting Sales Tax and then refunding is not only an exercise in futility but involves precious time of FBR Staff and also burdens the foreign exchange earning exporters in unnecessary hurdles and indefinite blockade of their sorely needed liquidity causing extreme heartburn to them who have been instrumental in not only earning the largest amount of sorely needed foreign exchange for the country but also generating largest employment.
Bilwani rued the fact that despite several Expo Exhibitions being encouraged by the Government of Pakistan and tall claims of visits by large number of foreign buyers, unfortunately no increase in exports is witnessed. He appealed to the Business Friendly Government of Mian Muhammad Nawaz Sharif to be really pragmatic and seriously review such futile exercises of the Government aimed to boost exports and ensure result oriented measures such as providing forthwith zero rating facility to the five export sectors; immediate and speedy release of held up funds of the exporters with the Government; reduce of cost of inputs - gas, electricity, water tariff etc and bring at par with our regional competitors, all of which are most essential requirements of the exporters.-PR

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