Check Pakistan’s 2026 Section 236C and 236K property tax rates for filers, non-filers and overseas Pakistanis, plus PSID and exemption rules.
By Syed Asad Hussain Zaidi · 5 September 2026
If you are buying or selling property in Pakistan in 2026, check your Active Taxpayer List (ATL), commonly called filer status, before creating the property challan. Under the current law, Section 236C charges an ATL seller 2.75%, while Section 236K charges an ATL buyer 1.25%. Non-ATL rates can rise as high as 18.5% for a buyer.
[Finance Act 2026 Framework]
- Section 236C’s filer rate changed from progressive rates of 4.5%–5.5% to a flat 2.75%.
- Section 236K’s filer rate changed from 1.5%–2.5% to a flat 1.25% under the controlling consolidated Ordinance.
- The separate Tenth Schedule late-filer rate table was omitted by Finance Act 2026.
FBR’s Budget 2026–27 salient-features document says Sections 236C and 236K were converted to flat rates of 2.75% and 1.5% respectively.
However, the subsequently consolidated Income Tax Ordinance amended to 30 June 2026 states that Section 236K is 1.25% of fair market value. TaxCalc.pk’s 2026–27 Tax Card also records 1.25%.
This guide therefore uses 1.25% for Section 236K because the controlling consolidated legislation takes precedence over a budget-summary document.
Check the TaxCalc.pk Tax Card 2026–27.
Section 236C is advance income tax collected from the seller or transferor when immovable property is registered, recorded or transferred. Section 236K applies to the buyer or transferee at the same transaction stage.
The two sections use different tax bases:
This distinction matters when the declared sale consideration and the value used for tax purposes are different.
The collecting person can include a registrar, local authority, housing authority, housing society, co-operative society, regulated property project or another person responsible for registering or recording the transfer.
For a person appearing on the ATL, Finance Act 2026 replaced the previous property-value brackets with flat rates.
| Property transaction | ATL / filer rate | Non-ATL rate | | :--- | :--- | :--- | | Seller — Section 236C | 2.75% of gross consideration | 11.5% | | Buyer — Section 236K, FMV up to Rs.50 million | 1.25% of FMV | 10.5% | | Buyer — Section 236K, FMV above Rs.50m up to Rs.100m | 1.25% of FMV | 14.5% | | Buyer — Section 236K, FMV above Rs.100 million | 1.25% of FMV | 18.5% |
The ATL rates come from Divisions X and XVIII of Part IV of the First Schedule. The higher non-ATL rates arise through the Tenth Schedule.
The current Division X states a flat rate of 2.75% of the gross consideration received. For a seller outside the ATL, the Tenth Schedule prescribes 11.5% on the gross consideration.
The current Division XVIII states a flat 1.25% of the fair market value for the normal rate. A buyer outside the ATL faces the separate Tenth Schedule table of 10.5%, 14.5% or 18.5%, depending on property value.
Finance Act 2026 substantially reduced the advance-tax burden for taxpayers receiving the normal ATL rate.
| Gross sale consideration | Previous ATL rate | Current 2026 ATL rate | | :--- | :--- | :--- | | Up to Rs.50 million | 4.5% | 2.75% | | Above Rs.50m up to Rs.100m | 5.0% | 2.75% | | Above Rs.100 million | 5.5% | 2.75% |
The current consolidated Ordinance records the earlier 4.5%, 5% and 5.5% table in its amendment history and replaces it with the 2.75% flat rate.
| Fair market value | Previous ATL rate | Current 2026 ATL rate | | :--- | :--- | :--- | | Up to Rs.50 million | 1.5% | 1.25% | | Above Rs.50m up to Rs.100m | 2.0% | 1.25% | | Above Rs.100 million | 2.5% | 1.25% |
The consolidated Ordinance records the previous 1.5%, 2% and 2.5% brackets and the current 1.25% rule.
Yes. The separate Rule 1A of the Tenth Schedule, which contained special Section 236C and 236K rates for people appearing on ATL after filing late, was omitted by Finance Act 2026.
Before its omission, Rule 1A contained seller rates of 7.5%, 8.5% and 9.5%, and buyer rates of 4.5%, 5.5% and 6.5%, depending on transaction value. Those tables are now historical.
The current distinction is therefore driven primarily by whether the person is actually appearing on the ATL when the transaction is processed.
A person filing a return after the due date may obtain ATL inclusion after satisfying Section 182A. Current surcharge amounts are:
| Taxpayer | Post-deadline ATL surcharge | | :--- | :--- | | Individual | Rs.25,000 | | Association of Persons | Rs.50,000 | | Company | Rs.100,000 |
Section 182A states that a late filer can be included in ATL after filing and paying the applicable surcharge.
For an individual, Section 182A(3) also provides an undertaking mechanism linked to not purchasing or acquiring property for six months. Its prescribed form and practical Iris implementation should be checked before relying on it.
The cash-flow difference can be substantial.
Assume the seller’s gross consideration and the buyer’s applicable fair market value are both Rs.40 million.
| Taxpayer | ATL tax | Non-ATL tax | Difference | | :--- | :--- | :--- | :--- | | Seller — 236C | Rs.1,100,000 | Rs.4,600,000 | Rs.3,500,000 | | Buyer — 236K | Rs.500,000 | Rs.4,200,000 | Rs.3,700,000 |
For the buyer alone, being outside ATL creates an additional upfront collection of Rs.3.7 million.
| Taxpayer | ATL tax | Non-ATL tax | Difference | | :--- | :--- | :--- | :--- | | Seller — 236C | Rs.2,062,500 | Rs.8,625,000 | Rs.6,562,500 | | Buyer — 236K | Rs.937,500 | Rs.10,875,000 | Rs.9,937,500 |
| Taxpayer | ATL tax | Non-ATL tax | Difference | | :--- | :--- | :--- | :--- | | Seller — 236C | Rs.4,125,000 | Rs.17,250,000 | Rs.13,125,000 | | Buyer — 236K | Rs.1,875,000 | Rs.27,750,000 | Rs.25,875,000 |
This is why ATL status should be verified before the PSID is generated and before money is committed to completion.
Generally, yes. Section 236C states that advance tax collected from the seller is adjustable. This means it can normally be claimed as tax credit when calculating the taxpayer’s final income tax liability.
There are important exceptions:
Property bought and sold in the same tax year Where the immovable property is acquired and disposed of within the same tax year, Section 236C states that the collection becomes minimum tax. That distinction can materially affect a short-term property transaction.
Certain overseas transactions through FCVA or NRVA Section 236C also contains a separate rule for qualifying non-resident individuals who acquired property through a Foreign Currency Value Account (FCVA) or Non-Resident Rupee Value Account (NRVA). Where its conditions are met, the collection can operate as final discharge of the capital-gain liability.
Do not treat every overseas Pakistani property sale as final tax. The account, acquisition funding, residence and identity conditions must be established.
Yes. Section 236K states that the advance tax collected from the purchaser is generally adjustable. The buyer should retain the computerized payment receipt (CPR) and confirm that the payment appears against the correct CNIC or NTN.
Section 236K also contains separate treatment for qualifying non-residents using specified foreign-currency or non-resident rupee accounts. Those cases should be reviewed separately before the collection is described as final.
Yes, in a qualifying case.
Clause 111AC of Part IV of the Second Schedule provides that Section 100BA and Rule 1 of the Tenth Schedule do not apply to a non-resident individual holding a POC or NICOP for transactions subject to Sections 236C and 236K.
This is the legal basis for giving certain overseas Pakistanis the normal filer-rate treatment even where their name is not appearing on ATL.
FBR’s overseas guidance states that the facility applies where:
No. It gives qualifying overseas Pakistanis the filer transaction rate for Sections 236C and 236K. It does not automatically place their name on the Active Taxpayer List.
That distinction matters for bank profit, vehicles, dividends and other transactions where a separate ATL rule may apply.
Where Clause 111AC applies, the Tenth Schedule non-ATL enhancement does not apply. The current normal rates should therefore be used:
| Overseas transaction | Current normal rate | | :--- | :--- | | Sale — Section 236C | 2.75% | | Purchase — Section 236K | 1.25% |
The exact overseas eligibility should be verified before the PSID is generated.
[!WARNING]
Important warning about FBR’s overseas FAQ: FBR’s overseas FAQ remains useful for the POC/NICOP and residence conditions. However, search results from that page still display the earlier property-rate tables in places. For a 2026 transaction, the rate should therefore be cross-checked against the Finance Act 2026 and consolidated Ordinance, rather than relying only on an older FAQ table.
Yes, but it is narrower than the general overseas filer-rate facility.
Section 236K(4) states that the section does not apply to a scheme introduced by:
This is an exemption from Section 236K for qualifying schemes. It should not be extended to every private housing project marketed to overseas Pakistanis.
Before claiming it, confirm:
A separate exemption-certificate mechanism exists under Section 159(1B).
The Commissioner must issue a Section 236C exemption certificate where the specified conditions are satisfied and the capital gain is not chargeable under Section 37(1A). The residential property must:
The exemption certificate is available once in 15 years. This is not an automatic exemption at the registrar’s office. The seller should obtain the prescribed certificate before transfer.
No. Section 236C is primarily an advance tax collection at the property-transfer stage. Capital gains are separately determined under the relevant capital-gain provisions.
A seller may therefore have:
The exception is where a specific rule makes the Section 236C collection minimum or final tax. Do not calculate the final capital-gain liability by simply multiplying the sale price by 2.75%.
No. Section 236K is only one component of the transaction. A purchaser may also face:
Those charges are jurisdiction-specific and should not be called FBR income tax. Section 236K itself is federal advance income tax administered under the Income Tax Ordinance.
The person responsible for registering, recording or attesting the transfer collects the tax. The Ordinance expressly extends this to persons acting for:
The tax should be deposited against the correct taxpayer details so the CPR can later be verified in the income tax record.
FBR maintains a dedicated overseas-property area that includes a facility to Create PSID under section 236C or 236K. Exact portal labels may change, so verify the live screen before payment.
For an overseas filer-rate claim, verify the NICOP or POC and non-resident evidence before finalising the challan.
Do not treat the generated PSID as correct simply because the portal produced it. Check:
A wrong status can change the collection by millions of rupees.
The 2026 framework moves the normal ATL property tax away from progressive brackets and toward low flat rates.
| Issue | Previous framework | Current 2026 framework | | :--- | :--- | :--- | | Section 236C normal rate | 4.5%–5.5% | 2.75% flat | | Section 236K normal rate | 1.5%–2.5% | 1.25% flat | | Separate late-filer property table | Yes | Omitted | | Non-ATL Section 236C | 11.5% | 11.5% | | Non-ATL Section 236K | 10.5%–18.5% | 10.5%–18.5% | | Overseas POC/NICOP filer-rate facility | Available | Continues |
The rate reduction is confirmed by the current First Schedule, while Rule 1A’s omission appears in the Tenth Schedule amendment history.
| Stage | Timing | Action | | :--- | :--- | :--- | | Before negotiating | Before PSID | Check ATL and overseas status | | Before property transfer | Before registration | Obtain any required exemption or lower-rate certificate | | PSID creation | Before payment | Select 236C for seller or 236K for buyer | | Tax payment | Before or at transfer | Pay and obtain CPR | | Registration or transfer | Completion stage | Provide payment evidence | | Income tax return | Relevant tax year | Claim adjustable credit where applicable | | Post-filing | After return | Reconcile advance tax with final liability |
[!TIP]
TaxCalc Advisory Insights: Check status before the property deal reaches completion. The largest financial risk is often not the final capital-gain calculation. It is generating a property challan while the taxpayer is still showing as non-ATL. For a Rs.75 million purchase, the difference between the normal 1.25% buyer rate and the 14.5% non-ATL rate is almost Rs.10 million. Check the CNIC, ATL status and rate before paying the PSID.
Author Note: Updated September 2026 by TaxCalc.pk Editorial Team, TaxCalc.pk.
Disclaimer: Tax laws in Pakistan shift rapidly via SROs and circulars issued by the FBR. While this guide is current for Tax Year 2026, it does not constitute formal legal or financial advice. Always cross-reference your calculations with a registered tax practitioner or the official FBR Iris portal before submission.
Legal & Statutory Notice: The information provided in this publication is for general educational, academic, and statutory informational purposes only under the relevant laws of Pakistan (including the Income Tax Ordinance, 2001, the Companies Act, 2017, and the Trade Marks Ordinance, 2001). This content does not constitute formal legal, financial, or tax advice. For specific assessments, consult a licensed Advocate or qualified tax professional.