IHC Rules Telecom's Tower Deal Taxable
- On June 13, 2025, the Islamabad High Court, through a panel of judges, ruled that the 2018 transfer of tower assets by a major telecom company is subject to taxation within Islamabad.
- The case originated from the telecom operator’s 2018 internal transfer of its nationwide tower assets to a fully owned subsidiary, which the operator argued should be exempt from taxation under the relevant provisions of the Income Tax Ordinance governing intra-group transfers.
- The court dismissed the operator’s argument, ruling the transaction valued at $940 million violated section 97 since no conditions for tax deferral were met, and it upheld FBR’s authority to assess accounting income as taxable.
- The telecom operator recorded an accounting gain of Rs75.9 billion from the Rs98.5 billion disposal, leading to an assessed tax liability of approximately Rs22 billion , with Rs100,000 costs imposed on the petitioner.
- This landmark ruling reinforces the Federal Board of Revenue’s jurisdiction over high-value intra-group transfers, indicating such gains cannot defer taxation and must be recognized promptly under Pakistan’s tax law.
12 Articles
12 Articles
High court rules in favor of FBR, telecom operator liable for Rs22 billion tax on tower asset transfer - Profit by Pakistan Today
Telecom operator transferred tower assets to its subsidiary in 2018 for Rs98.5 billion, recording a gain of Rs75.9 billion, but argued the transaction was exempt from tax
IHC rules telecom's tower deal taxable
A Division Bench of the Islamabad High Court (IHC), led by Justice Babar Sattar, has recently delivered a significant ruling in favour of revenue in a tax reference filed by a major telecom operator. The ruling upholds the powers and jurisdiction of the Federal Board of Revenue (FBR) in assessing tax liability on a high-value intra-group transaction involving the transfer of telecom operator's tower assets. As a result, the telecom operator is n…
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