Blog/Tax Updates

FBR Weekly Tax Update: Footwear POS Rules and New Litigation Scrutiny Proposals

Tehsin Associates
24 July 2026
Editorial illustration of a footwear point-of-sale terminal, tax documents, courthouse and customs container

What FBR changed between 17 and 22 July 2026

The Federal Board of Revenue published a cluster of measures affecting footwear supply chains, tax litigation and customs cargo. They do not all have the same legal status. Sales Tax General Order No. 11/2026 is an operative clarification with effect from 1 July 2026, and S.R.O. 1130(I)/2026 makes final amendments to the customs transshipment rules. By contrast, S.R.O. 1138(I)/2026 and S.R.O. 1141(I)/2026 expressly publish draft scrutiny-committee rules for comments. Businesses should act on the final measures but should not treat the drafts as law yet.

Footwear sold through integrated POS chains gets a defined sales-tax treatment

The Finance Act 2026 added footwear of all types to Serial No. 65 of the Third Schedule to the Sales Tax Act, 1990, subject to an exception where a manufacturer sells exclusively through its own FBR digitally integrated and POS-compliant outlets. FBR then issued Sales Tax General Order No. 11/2026 on 17 July to address how the rule works across documented supply chains.

The order places four situations outside the retail-price-based regime under Serial No. 65:

  • A registered manufacturer supplies footwear through its own FBR-integrated, POS-compliant outlets.
  • An importer supplies registered manufacturers or FBR-integrated, POS-compliant retailers.
  • An FBR-integrated, POS-compliant retailer imports goods directly for sale to consumers.
  • A digitally integrated registered manufacturer or registered importer supplies a registered corporate entity, government department, autonomous body or statutory body for its own use.

For those cases, sales tax is charged on the value of supply under section 2(46). For imports covered by Serial No. 65, the order states that tax is assessed on 130% of the customs value determined under section 25 of the Customs Act, including applicable customs duties and Federal Excise Duty. The order applies from 1 July 2026.

Footwear manufacturers, importers and brand retailers should check that their registrations, POS integration, invoices and customer classifications support the treatment they claim. The relief depends on a documented and electronically verifiable chain, not merely on using a point-of-sale terminal.

Income-tax litigation scrutiny is a proposal, not a final rule

S.R.O. 1138(I)/2026, dated 21 July, proposes new Income Tax Rule 231CB for independent case scrutiny committees. The draft gives affected persons three days from publication in the official Gazette to send objections or suggestions to FBR.

The proposed committees would examine whether FBR should file a reference before a High Court or a petition before the Supreme Court or Federal Constitutional Court. They would also review pending litigation, maintain a database of settled legal questions, and identify recurring issues that may need legislative or administrative action.

Under the draft, a Commissioner would refer a case within ten days of receiving the relevant ATIR or High Court order. The committee would normally finalize its recommendation within fifteen days. If it did not decide within the permitted time, the case would be treated as cleared for filing, subject to the other legal requirements. These are proposed procedures only; their practical effect depends on the wording of any final notification.

Customs litigation has a parallel draft framework

S.R.O. 1141(I)/2026, dated 22 July, publishes draft Independent Case Scrutiny Committee (Customs) Rules, 2026 and allows seven days from publication in the official Gazette for objections or suggestions.

The draft proposes four territorial committees covering North, Central, South-I and South-II. It would make pre-filing scrutiny mandatory before a customs reference or petition is filed, route the process through a dedicated PSW portal or modified WeBOC system, and set a fifteen-day decision target with a possible ten-day extension. A case not decided within the permitted period would be deemed cleared for filing.

Although the text of the proposed rules says they would come into force at once, the covering notification expressly identifies them as a draft for consultation. Taxpayers and advisers should therefore monitor FBR for a final notification before relying on the proposed process.

International transshipment rules have already changed

S.R.O. 1130(I)/2026, dated 17 July, makes final amendments to the Customs Rules, 2001 for international transshipment cargo. Among other changes, container and seal numbers are required only for containerized cargo; port-to-port movement must use licensed bonded carriers under the cargo tracking rules; packing of dry bulk cargo may be allowed under Customs supervision; and the normal movement period is differentiated between containerized cargo and bulk or less-than-container-load cargo. The amendments also provide for risk-based scanning and limited extensions in exceptional cases.

Shipping lines, bonded carriers, terminal operators and importers using international transshipment should update operating instructions and document controls against the final text rather than relying on the earlier draft.

What affected businesses should do now

  • Footwear businesses: map each supply route to the implementation matrix in Sales Tax General Order No. 11/2026 and retain evidence of FBR POS integration and customer status.
  • Tax litigants and advisers: review the two scrutiny-committee drafts, confirm the official Gazette publication dates, and submit comments within the applicable window if affected.
  • Customs and logistics operators: update transshipment procedures for the final S.R.O. 1130 requirements, especially cargo identifiers, bonded movement, timelines and scanning.
  • Everyone: keep the final orders separate from the drafts in internal advice, contracts and compliance checklists.

Official FBR sources

The bottom line

This week's most immediate compliance change is the footwear sales-tax implementation matrix, effective from 1 July, together with the final customs transshipment amendments. The scrutiny-committee frameworks point toward more structured FBR litigation decisions, but they remain consultation drafts until finalized.

Disclaimer: This article summarizes official FBR documents reviewed on 24 July 2026 and is general information, not legal or tax advice for a particular transaction. Gazette publication dates, later amendments and final notifications should be checked before acting.

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