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FBR exempts same-STRN warehouse transfers from digital invoicing

ISLAMABAD: The Federal Board of Revenue has said goods moved from a factory to the registered personโ€™s own warehouse do not require a digital invoice if both premises operate under the same sales tax registration number.

The clarification was issued in Sales Tax General Order No. 25 of 2026. The FBR said such movement does not constitute a taxable supply because ownership does not change and no consideration is involved.

Businesses must, however, prepare and carry a sequentially numbered Stock Transfer Note with every consignment. The document must identify the dispatching unit, receiving warehouse, goods, quantity, vehicle and other prescribed details, and must be marked: โ€œStock Transfer โ€” Not a Taxable Supply.โ€

The value of the goods may be recorded at cost for inventory-control purposes but must not be presented or numbered as a tax invoice. The receiving warehouse must acknowledge the consignment, while both locations must update their stock registers and retain the records for six years, the order said.

The exemption does not apply when the receiving warehouse has a separate sales tax registration number. In that case, the movement will be treated as a taxable supply, requiring digital invoicing through a licensed integrator or the Pakistan Revenue Automation Ltd., with output tax accounted for in the normal manner.

The FBR also directed its field formations not to demand a driverโ€™s Computerized National Identity Card or documents other than the applicable digital invoice or Stock Transfer Note. Officials were instructed not to subject goods in transit to physical inspection, unloading or detention solely because a digital invoice was not issued.

Goods listed in the Third Schedule of the Sales Tax Act may still be checked to verify that the required retail price has been printed or embossed, the order said. Consignments traveling without either a tax invoice or Stock Transfer Note may be treated as prima facie undocumented.

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