Section 153 withholding: how ATL status matters

By CheckOne by FormOne · Updated 21 Oct 2026

Section 153 of the Income Tax Ordinance, 2001 requires prescribed persons (companies, AOPs and others named in the law) to withhold tax when they pay for:

• s.153(1)(a): the sale of goods,
• s.153(1)(b): the rendering of services,
• s.153(1)(c): the execution of contracts.

The rate depends on the section, on whether the payee is a company, an individual or an AOP, and on whether the payee is on the Active Taxpayer List.

Payees not on the ATL

Under the Tenth Schedule, the rate for a payee who is not on the ATL is generally increased, in many cases to double the normal rate. The exact figures change with each Finance Act, so we show them from a dated, versioned rate table rather than in this article.

A payment-review checklist

1. Record the payment date and whether the underlying transaction is goods, services or a contract.
2. Confirm the payee’s identifier and legal type against the documents supplied. A similar name is not a match.
3. Keep the ATL result together with the file’s publication date and the time the check was made.
4. Ask your advisor to confirm the applicable tax-year rate, section and any exception. Record the rate-table version used.

If a vendor’s status changes

A Monday alert is a prompt to review affected payments. Check the identifier and source dates before drawing a conclusion. A later file cannot establish the vendor’s status on an earlier payment date. Keep the earlier evidence and the new result separately, and refer the payment facts to your advisor.

Fictional example: a change between checks

A vendor appears in a file published on 5 October and is absent from a file published on 12 October. For a payment on 9 October, retain the 5 October source and the payment record. Do not relabel the older result using the 12 October file, or infer the exact day the status changed. Your advisor assesses whether further evidence is needed.

What we show, and what we do not

• We show FBR's published rate for the section and payee type, and which version of our rate table it came from.
• We do not calculate the amount, apply exemption certificates under section 159, or apply reduced-rate notifications. Your advisor decides those.

The status that matters is the payee's status on the payment date, so keep a dated record of the check. Why that record matters.

Official sources and scope

• FBR: daily ATL updates and the revised annual transition (S.R.O. 1638(I)/2024)
• FBR income-tax and sales-tax ATL downloads
• FBR withholding tax rate cards by tax year
• FBR Sales Tax Act publications
• FBR Income Tax Ordinance publications

General information, not tax advice. Verify the rules and source dates applicable to your transaction with your advisor. This guide does not publish an independently approved rate table.