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ISLAMABAD: The Federal Board of Revenue (FBR) has strengthened the Directorate General of International Tax Operations to effectively interact with the foreign tax jurisdictions, automatic exchange of information from other countries and other global tax matters.

According to a notification issued by the FBR here on Wednesday, the competent authority has approved the revised strength of officers (BS-17 and above) of the Directorate General of International Tax Operations, Islamabad with immediate effect.

The Directorate General of International Tax Operations would work more effectively in dealing with the foreign tax jurisdictions.

The Directorate General of International Operations has already become fully operational for the imposition and recovery of taxes from undisclosed offshore assets and income held by Pakistanis abroad and to interact directly with foreign tax jurisdictions for exchange of information.

Under the revised structure, out of total nine posts, the existing posts included Director General; Chief/Director (International Tax-Operations); Secretary /Addl Director (Country-by-Country - Reporting and Transfer Pricing); Secretary/ Additional Director (International Taxes - Operations); Secretary (UN Tax Committee); Chief Director (International Taxes); Secretary/ Additional Director (Tax Treaties and Conventions); Secretary/ Additional Director (Automatic Exchange of Information) and Secretary/ Additional Director Exchange of Information).

The concerned Wing shall not deviate from the above approved strength in any case and will not re-designate, re-organise the approved strength or change nomenclature of any post without approval of the chairman, FBR/Secretary, Revenue Division and all such cases shall invariably be referred to Admin/HR Wing for requisite input, as the HRIS System is aligned with above approved re-organisation, the FBR notification said.

The directorate has the authority to enforce return filing, make assessments, seek automatic exchange of information from other countries and obtain information of taxpayers solicited by another country under tax treaty, tax information exchange agreement or multilateral convention.

The Director General of International Taxes Operations has the jurisdiction over persons or classes of persons carrying on business or residing in areas, within the territorial jurisdiction of Pakistan.

The Director General of International Taxes Operations may enter into a tax treaty, a tax information exchange agreement, a multilateral convention, an inter-governmental agreement or similar agreement or mechanism for the avoidance of double taxation or for the exchange of information for the prevention of fiscal evasion or avoidance of taxes including automatic exchange of information with respect to taxes on income imposed under Income Tax Ordinance or any other law for the time being in force and under the corresponding laws in force in that country.

The Director General of International Taxes Operations shall have the powers to obtain and collect information solicited by another country under a tax treaty, a tax information exchange agreement, a multilateral convention, an inter-governmental agreement, a similar arrangement or mechanism.

The Director General of International Taxes Operations would be empowered to exercise anti-avoidance provisions under the Chapter VIII of Income Tax Ordinance 2001. The Director General of International Taxes Operations would have the authority to deal with the controlled foreign companies. He can exercise powers pertaining to the unexplained income or assets and liability in respect of certain security transactions.

The Director General of International Taxes Operations would be empowered to enforce filing of returns and making or amending assessments under the Chapter X of the Income Tax Ordinance 2001. He would be empowered to delegate to any officer of Inland Revenue, subordinate to the Commissioner all or any of the powers or functions conferred upon or assigned to the Commissioner under this Ordinance, other than the power of delegation.

The Director General of International Taxes Operations may, in respect of any transaction between persons who are associates, distribute, apportion or allocate income, deductions or tax credits between the persons as is necessary to reflect the income that the persons would have realised in an arm’s length transaction. In making any adjustment, the DG may determine the source of income and the nature of any payment or loss as revenue, capital or otherwise.

Copyright Business Recorder, 2022

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