Dr. Ikramul Haq
The Business Recorder on 12 August 2011, under the title, FBR: A divided house , published an article, some excerpts of which need to be reproduced in verbatim. The purpose of reproducing these is to highlight that even after about 10 years, we have still failed to achieve what was then conceived and presented. It shows that our rulers, policymakers and tax collectors are not ready for a paradigm shift in policy and administration. For making Federal Board of Revenue (FBR) an effective and taxpayer friendly body, there is lack of political will. At the end, some concrete proposals are given to recoup what we lost during the last many decades. First of all the important excerpts of the article written jointly with Huzaima Bukhari:
“……Our sole aim has always been to highlight the fact that this important institution has become ineffective due to political interferences and maladministration. Many a times, we have suggested that FBR should be a truly autonomous authority, as is the case with many countries, with a foolproof system of checks and balances to ensure proper revenue collection. Pakistan is in dire need of raising taxes to the level of Rs. 4 billion at least—though the real potential is Rs. 8 trillion.
In the wake of what happened at 4th Chief Commissioners’ Conference, held in Islamabad on 4 August, 2011 and thereafter in the meeting of Board-in-Council on 8 August 2011, we sincerely believe that FBR should be made autonomous authority without any further delay. The autonomous FBR should be independent, efficient, well equipped, competent and fully automated. This is the only way to ensure that FBR performs its role of revenue generation at optimal level with justice and diligence. Unless it works justly, efficiently and proactively, Pakistan cannot come out of the debt prison—our total internal and external debt crossed the figure of Rs. 13 trillion as on 30 June 2011. Unfortunately, the FBR’s stalwarts have always joined hands with the political elite of the day and played in their hands for getting lucrative posts and undue benefits. Instead of tightening the noose around tax evaders they concentrate more on extending full support to their political masters in looting wealth of the nation, transfer it outside and give them full protection from taxation.
The Report said that theConference was stunned as soon after the inaugural speech of the FBR Chairman, the Member Inland Revenue (IR) Mr. Khawar Khurshid Butt categorically informed the participants that his powers of transfers and posting stood withdrawn since April 2, 2011. He was quoted in the report:
“My powers have been taken away and neither can I transfer any person nor post anyone in the field formations. If the FBR gives us revenue collection targets, the Board should also empower the concerned authority for completion of the job. Nobody in the field formations is ready to implement his orders”.
The ineffectiveness of FBR once again emerged during the Board-in-Council meeting when it was revealed that around Rs. 84 billion inadmissible tax adjustments were claimed by “unscrupulous elements”. Nobody asked the question how these elements succeeded to get this unlawful adjustment. Was it possible without the connivance of tax officials? Is FBR system is no pathetic that anybody can claim inadmissible tax adjustment? The FBR stalwarts instead of going for corrupt elements within FBR, according to the report, “decided to investigate and verify the amount of Rs. 84 billion inadmissible tax adjustments claimed by the registered persons”.
The above proves beyond any doubt that FBR as it exists now has become a useless entity. Its failure can be gauged from a single fact that at the end of US$ 100 million World Bank funded Tax Administration Reform Project (TARP), the tax-to-GDP ratio dipped to 8.2 per cent from 10.6 per cent. The borrowed funds of millions of dollars were ruthlessly wasted and today FBR House is hub of internal strife. The Parliamentary Standing Committee on Finance should conduct a thorough probe in the matter and seek the assistance of tax experts to determine the amount of loss caused to national exchequer by FBR stalwarts during the last two decades, especially regarding non-collection of taxes where due and illegal exaction when nothing was payable.
It is admitted by FBR that even after “great efforts” (sic) less than 1.5 million Pakistanis filed income tax declarations for tax year 2011. FBR has failed to implement law even in Islamabad as out of 43000 commercial and residential rental properties in Islamabad, only 7000 owners are filing returns. In Pakistan, the number of mobile users alone, who pay more than Rs. 100,000 as annual bill, is about 1,500,000. Why have they not been compelled to file returns? Does FBR need any further evidence to demonstrate its inefficiency and ineffectiveness? At least the FBR stalwarts cannot convince informed people of its “wonderful performance” by just maneuvering and playing with figures.
FBR is guilty of criminal negligence in not taxing persons having taxable income, but extorting money from many who earn below taxable income—majority of the people subjected to withholding taxes have below taxable incomes…… It is just thriving on withholding taxes and voluntary payments—constituting 92% of total collection. The contribution of field officers [collection on demand through investigation or audit] is just 8% of total collection proving beyond any doubt how unproductive this organisation is becoming.
The inefficient and corrupt tax apparatus is the root cause of the present pathetic state of affairs. The tax officials persistently and ruthlessly squeeze and penalize existing taxpayers while collaborating with tax evaders—massive evasion is not possible without their abetment. The small business houses and salaried persons, already heavily taxed through withholding tax mechanism, are victims of their highhandedness. It is high time that the FBR should put its own house in order and tax the rich and mighty tax evaders…”
Note: Those interested to read the full article can do so by visiting the following link:
We are where we were 10 years ago
In the wake of fourth deadly wave of coronavirus with delta variant and challenges, the Prime Minister, Imran Khan, has tweeted the following:
“I commend efforts of FBR in achieving record revenue collection in July. As of now collection is Rs.410 bn which is highest ever in month of July – & around 22% above required target for the month. This is a reflection of govt’s policies for sustained economic growth & revival”.
The questions posed on 4 August 2011 remain unanswered. Have we collected sufficient funds to come out of deadly debt trap and taken care of the less-privileged as well as the downtrodden? For meeting all these challenges 10 years back, the collection by FBR now after 10 years should have been Rs. 10 trillion, if not more. However, it was possible only if the reforms suggested were implemented. The result is before us. For the immediately preceding year, FBR barely reached 50% of the actual potential and after transfer to provinces under the National Finance (NFC) Award and debt servicing, nothing worthwhile was left to meet day to day expenses what to speak of infrastructure development and providing social services to all.
The above shows that regimes have changed but not the mindset of leaders, parliamentarians and tax collectors though billions have been borrowed in the name of tax reforms. We are where we were a decade ago. This inertia is our real dilemma that nobody wants to address, overcome and move forward.
Is celebration of exceeding target justified or not? The areas highlighted in the following report need consideration by all:
- “But more than half of the tax collection at the import stage is in line with the government’s new policy of relying on indirect taxes to achieve the annual target after it could not broaden the tax base that remained skewed during its first three years.
- The FBR collected over Rs410 billion during the first month of fiscal year 2021-22 as against the monthly target of Rs341.7 billion, according to statistics compiled by the revenue board on Friday. The monthly collection was equal to 7% of the annual target.
- The Rs410 billion provisional collection was higher by 36.5% or Rs109 billion over the revenue generated during the same month of last fiscal year.
- Like the previous fiscal year when the FBR had exceeded July’s target by Rs57 billion, it has again taken a good start of the new fiscal year.
- Out of the Rs410 billion, the FBR collected Rs210 billion at the import stage, which was equal to 51.3% of the total monthly collection.
- The heavy reliance on import taxes and duties may cause inflation in the country, as taxes paid at the import stage are usually recovered by increasing the prices. These import taxes are also causing an increase in prices of electricity and petroleum products.
- In the budget, the government had imposed 17% sales tax on crude oil import. It also doubled customs duty rate from 5% to 10% on the import of petrol to achieve the tax target.
- There were also some other indirect measures in the budget like 75 paisa federal excise duty on each telephone call exceeding five minutes.
- The share of income tax in total revenue sharply fell to just 32.7%, which has put more burden on people who have less capacity to pay.
- The FBR collected 67.5% or Rs277 billion in indirect taxes – general sales tax, customs duty and federal excise duty which are the three main sources of indirect taxes.
- The Pakistan Tehreek-e-Insaf (PTI) election manifesto had promised to increase the share of direct taxes to 45% from 38%.
- Finance Minister Shaukat Tarin had said last month that being a developing country, the share of indirect taxes would increase in the short term.
- Tax-wise collection
- The FBR collected Rs134 billion under the head of income tax – up by Rs31 billion or 30% over the same month of last year.
- The collection was Rs40 billion higher than the target as the FBR had set a low income tax target due to poor performance in the last fiscal year. But advance income tax payments by banks helped the FBR surpass the monthly income tax target, said an official of the tax machinery.
- The FBR showed 44% growth in sales tax collection in July, due to heavy reliance on import taxes. The tax machinery collected Rs190 billion in sales tax – higher by Rs58 billion.
- However, 65% of the total sales tax collection was at the import stage in which the taxmen did not have any role.
- Out of the Rs190 billion, an amount of Rs124 billion was collected at the import stage – up by Rs46 billion or 60%, according to the provisional figures.
- The growth in domestic sales tax collection was 25%, which suggested the picking up of economic activities in the country.
- The federal excise duty collection stood at Rs22.3 billion, which also increased over 20% and was equal to the monthly target.
- Pakistan Customs collected Rs66 billion under the head of customs duty – up by nearly 35%.
- One of the reasons behind the disagreement between Pakistan and the International Monetary Fund (IMF) over the completion of sixth review is the IMF’s position that there was between Rs300 billion and Rs350 billion gap between the Rs5.829 trillion target and the measures taken to achieve that.
- The finance minister has said that the FBR can deliver the target without taking additional revenue measures”.
FBR’s defence as usual is not based on any solid grounds as continuation of past tax policies by political masters is the main impediment for change. They have no other way but to create economic distortions, mint millions at import stage by false declarations and in the end making the economy uncompetitive in the global markets. Above all, they are promoting the culture of rent seeking and forcing/inducing businesses to conceal true facts. When in these columns it is repeatedly said to collect sales tax when actual sales take place and income tax when income is crystalized, and restrict withholding to salary, dividend, interest and payments to non-residents (if taxable), they oppose for obvious reasons as their financial lifeline (self-aggrandizement) will end. At present only a few thousand companies are paying 90% of total tax collection. The devil is in the details. FBR hides the factual position and all prime ministers and their advisors since 1991-1992 though understand the reality of FBR’s own efforts (not more than 5% to 8%) yet pose as if wonders have been achieved. The total potential is double the amount FBR is presently collecting. The rest is forgone due to incompetence, capacity issues or connivance. Till today no trace and track has been introduced for major industries, massive under-invoicing in imports and over-invoicing the exports confirm that something is fundamentally wrong with the existing tax system. Exporters selling in local markets showing all production as 100% exports, smuggling, mis-declarations and mis-classification at import stage, are common knowledge. The Customs and IRS are hubs of inefficiency and/or corruption—time and again exposed in various articles, reports and books, proving exercise in futility. The administration is made toothless and corrupt by design. The following is the area most hidden from the public eye:
Weeding out deadwood
In continuation of earlier article [Weeding out “deadwood”, Business Recorder, April 30, 2021] and in response to objections raised by officers belonging to the Income Tax Officers (ITO) batch, points are further elaborated below to show that there is urgent need of weeding out deadwood from FBR despite the fact that they won their cases of seniority in the courts that was purely on technical grounds that the appeal was barred by the time and nowhere the Supreme Court held that officers not belonging to Civil Services (CSS) Cadre can become part of the same unless so inducted under the Civil Servants Act of 1973.
In this article, it was mentioned that whatever was written was based on facts, supported by necessary documentary evidence available with FBR. Therefore, the question of causing “any kind of prejudice to any employee of FBR” does not arise at all. Rather, this pertains to induction of unqualified people in the critical policy-making positions in FBR’s top hierarchy.
It is an irrefutable fact that the post advertised by the Federal Public Service Commission (FPSC) of lower scale non-CSS slots attract more applicants as compared with institutionally recognised Central Superior Services (CSS) examination, held annually, where candidates apply on all Pakistan basis for entering into various cadres for which recruitment is required on the demand of Establishment Division, Islamabad. Therefore, their number is usually less.
For non-CSS posts, below grade 17, if 70,000 people apply for BS-16 positions in FBR, this does not qualify them to get seniority at par with CSS officers. Obviously, their first priority was to join FBR whereas CSS officers usually place IRS at number 4th or 5th in their preference, in some case even lower. No other Occupational Service or Group has allowed such inductions to officers except Inland Revenue Service (IRS) of FBR. Some Occupational Groups allow such inductions to highly experienced officers when they are close to their retirement. Therefore, it is necessary to timely retire the ITOs batch so that the top administrative positions are not held by officers not entering the service through CSS examination. This will be patently against the law and certainly going to cause an irreparable loss to a vital institution that collects revenues out of which 58.5 percent goes to the provinces under the prevailing National Finance (NFC) Award under Article 160 of the Constitution. Revenue generation at the moment is the most important need to meeting the challenge of burgeoning fiscal deficit and monstrous debt reaching the level of nearly 90 percent of GDP.
It was also clearly mentioned that the ITOs batch was promoted at a very young age as Assistant Commissioner Inland Revenue in violation of rules and in excess of their approved quota. The 25 per cent quota is meant for all promoted officers including BS-16 Inland Revenue Officers (IROs) and other eligible officers from ranks. However, only the ITOs batch was promoted and inducted into the main IRS cadre which is unprecedented in the history of Civil Services of Pakistan. This was indeed a “back-door channel”.
It is pertinent to mention that before their promotion to Grade 19, a formidable resistance came from the then Member of Administration, who on an inquiry narrated the story as under:
“Throughout my stay I made sure this batch wasn’t promoted to next grade i.e. BA-19. It was tough though yet I succeeded. There’s this lady officer daughter of a ex- Federal Secretary and her mother an Additional Secretary, she is part of this group and was the reason behind absolutely unusual promotion of her batch to BS 17 from 16 in just 2 years of service. This feat should qualify to be listed in Guinea’s book of records. The culprit was…….Member Admin and …… Chairman, both spineless characters. FBR today is at its worst ever since its inception. This govt.’s handling is no better than before. There’s no silver lining in sight. A very unfortunate situation”.
Note: [The names of persons are omitted by me as purpose is to highlight illegality and it is up to Chairman FBR to move summary through Secretary Establishment to the Prime Minister to order the National Accountability Bureau (NAB) to take action as persons are government officers and the alleged irregularities must be investigated, providing all the accused a fair chance of defending their position before the matter is referred to Prosecution General of NAB to decide whether it is a fit case for trial or not].
The following facts are available on record:
- As per the record available with FPSC, most of the ITOs batch officers could not qualify the CSS examination. These factors put a question mark on their abilities to hold senior most positions in FBR.
- As far as the service of ITOs batch in Military Lands and Cantonment (ML&CG) is concerned, it also brought big embarrassment to FBR as their nominations were actually illegal. The basic facts are as follows.
- After the military coup by General Pervez Musharraf, inductions into ML&CG and Office Management Group (OMG) were halted. The ML&CG, therefore, sought requisition of suitable officers from various Occupational Groups and Services in 2006 for their induction as Cantonment Executive Officers (CEOs) on deputation basis.
- The above clearly meant that the CEO slots were for CSS officers from other service groups. However, the ITOs batch managed to get nominations from FBR and joined the ML&CG on deputation basis.
- After a few years, the ITOs batch tried to induct themselves in the ML&CG on regular basis. When their case was forwarded to the Director General (ML&CG) and Secretary (Establishment), they were shocked to observe that this batch was a bunch of non-CSS officers who not only served in the ML&CG illegally but were also trying to get themselves inducted into ML&CG on regular basis. They were immediately repatriated to FBR and both the DG (ML&CG) and Secretary (Establishment) categorically refused to induct them in the ML&CG as only CSS officers were eligible for such induction. If the ITOs batch was not inducted into the ML&CG, how could they get inducted into IRS main cadre? This was a sheer, rather blatant, violation of service rules and a “backdoor” induction into a CSS cadre.
Getting necessary departmental trainings such as Mid-Career Management Course (MCMC) and Senior Management Course (SMC) becomes meaningless when the very induction of officers was for non-CSS cadre. It is a well-established maxim that if the foundation of any action is unlawful, the subsequent actions have no sanctity—if the foundation is unlawful, the superstructure collapses as well. The mere completion of MCMC and/or SMC does not qualify the ITOs batch for induction into senior BS-20 slots. Such courses are attended and completed by many employees of the federal government who are not part of regular CSS cadre.
The Government must take note of the above and it they are not weeded out at this stage, the senior administration of FBR will be held by non-CSS officers in just a year or two. This is no less than a catastrophe for the coalition Government of Pakistan Tahreek-i-Insaf (PTI), led by Prime Minister Imran Khan, who was elected on the slogan of establishing rule of law and justice.
As far as judicial proceedings are concerned, there is always room for revisiting by the Supreme Court as the apex court is not slave of its own order. In a case reported as Shahid Pervaiz v Ejaz Ahmad and others 2017 SCMR 206, the Supreme Court of Pakistan held as under:
“This Court in the case of Hitachi Limited v Rupali Polyester (1998 SCMR 1618), has concluded that the Supreme Court is not a slave of doctrine of stare decisis and can change or modify its view with the passage of time. All the courts and public institutions are bound to follow the principles laid down by this Court. No exception to this principle can be created under the garb of rule or procedural niceties”.
The above judgement of the Supreme Court of 2017 is binding under Article 189 of the Constitution of Islamic Republic of Pakistan [“the Constitution”].
The above facts and legal position clearly establish that the promotion of ITOs batch to BS-20 as Commissioners of Inland Revenue (IRS) is not at all justified. The Chairman of FBR must take opinion of Secretary Establishment before nominating their names for promotion to Grade 20 as was earlier done by the DG (ML&CG).
The Secretary (Establishment) at that time held in unambiguous terms that only CSS officers were eligible for induction and promotion. In case, they are promoted to BS-20, the senior leadership of FBR will be in the hands of non-CSS officers in utter violation of the law of the land. If necessary action is not taken immediately, it will have serious ramifications for FBR as well as setting an unlawful precedent for civil services as mentioned in Article 240 of the Constitution and sub-legislation made thereunder.
FBR illegalities continue
According to a news story, “the Federal Board of Revenue (FBR) has obtained stay orders against the Federal Tax Ombudsman’s (FTO) decision to inspect offices dealing with offshore tax haven cases, blocking a move that could have unearthed reasons behind poor recovery of $22 million against $1.3 billion worth cases”.
The story raises the following vital questions:
- “It is rare that a government department has gone in the courts against a constitutional office that is responsible to check corrupt practices in the tax machinery. The matter appears serious as stay orders have been obtained to block the move to scrutinise offshore tax havens-related record, shared by Europe-based Organization for Economic Cooperation and Development (OECD) with Pakistan. FBR has secured multiple stay orders from Lahore, Islamabad, Peshawar and Sindh courts during the past few weeks, including two stay orders against the FTO’s decision to inspect Karachi and Islamabad Automatic Exchange of Information (AEOI) zones. The other stay orders were related to domestic tax cases being handled by Lahore, Faisalabad, Islamabad, Peshawar and Karachi offices.
- Due to complaints of “malpractices with corrupt motives”, the FTO office had taken a suo motu notice and launched probe to determine as to why FBR’s three field offices were failing the prime minister and the nation in recovery of presumably $200 billion stashed abroad.
- PM Imran Khan had promised to recover the $200 billion worth of looted money.
- The FTO, in April this year, had served notice on the FBR, directing it to nominate officials for inspection of the three zones. The FTO had ordered the inspection of all the three offices on complaints of malpractices with corrupt motives in the discharge of duties, falling within the ambit of maladministration.
- Now, the commissioners of the two zones have gone to the courts and gotten the FTO’s orders suspended.
- “It was not the decision of the board to file petitions in the courts rather this was individual action of the respective commissioners,” said Dr Muhammad Ashfaq, Director General International Taxes and Member Operations of the FBR while talking to The Express Tribune. He said that the FTO never shared the details of the alleged corrupt practices with the FBR.
- However, the move appears well-coordinated as these grade-20 officers cannot make such bold moves without support from their bosses.
- FTO Mushtaq Sukhera has also taken up the issue with President of Pakistan Dr Arif Alvi. However, the president instead advised him to take up the matter with Special Assistant to Prime Minister on Revenue Dr Waqar Masood Khan, according to sources privy to these discussions.
- Under the law, the FBR can file a representation before the president against the decisions of the FTO. But the FBR did not choose this legal path. “The FBR could have approached the president, had the decision to obtain the stay order been taken by the board,” said Dr Ashfaq in response to a question.
- The FTO took suo moto action after the official record disclosed that the FBR headquarters forwarded $2 billion worth of 1,579 cases to three AEOI zones of Karachi, Lahore and Islamabad but the recoveries in about 1,150 cases were a mere $30 million as of March.
- In case of Islamabad and Karachi, the recoveries were just below $22 million as of end March.
- The foreign currency accounts of Karachi AEOI zone reflect tax assessed was alarmingly low to the Lahore and Islamabad zones, according to the official documents. These papers showed that about 275 cases are yet to be decided out of total 899 assigned cases to the Karachi zone.
- The FBR headquarters forwarded Rs152 billion or nearly $1 billion cases to the Karachi zone, which recovered hardly $19 million or Rs3.1 billion. The zone had determined the taxable amount of just Rs22.8 billion. The sources said that the FTO wanted to ascertain whether the Karachi zone accurately made these assessments or there was mala fide behind it.
- Similarly, in case of Islamabad zone, the FBR forwarded Rs59.5 billion cases but the zone could recover hardly Rs305 million or $3 million.
- To make the investigation transparent, the FTO wanted to take an officer of the FBR nominated by the FBR chairman. But the FBR never gave its nomination and instead chose to go to the court.
- “If the FBR has not chosen to nominate its representatives on the proposed inspection teams, the FTO may proceed on its own without FBR representation as also referred to in your latest correspondence,” the FBR told the FTO on July 2.
- The FTO has also sought an explanation from the FBR chairman and member IR operations for not implementing its orders to nominate the officers.
- But the FBR informed the FTO that any further proceeding in the case may be pended till final disposal by the court cases, according to the FBR correspondence with the FTO office.
- While defending the FBR officers’ decision to knock the court doors, Dr Ashfaq said that the FTO never shared the details about the complaint and the name of the complainant that could have determined that there was any mala fide behind low tax recovery in offshore cases.
- He said that the entire OECD information was not actionable and there were many pitfalls”.
The point of view of Dr. Muhammad Ashfaq, DG International Taxes and also holding vital position of Member Operations (Inland Revenue) has been given by the scribe of the above story. He may be right that some witch-hunting is going on against FBR by the FTO. In such circumstances, the President can seek on what basis FTO initiated the proceedings.
The ultimate responsibility rests with the Federal Finance Minister, Shaukat Fayaz Ahmed Tarin, to ask the Chairman FBR to show cause the officers who have approached the Hugh Courts directly that amounts to misconduct under the Government Servants (Efficiency and Discipline) Rules, 1973 and through internal audit wing of IRS determine the alleged pilferage of revenues on the basis of information received from OECD. There are serious allegations that the officers are being protected by certain vested interest and image of Prime Minister is being tarnished who has made repeated pledges to uproot corruption from all spheres of governance.
The way forward
The only remedy is to structure the entire tax system of the country. It was elaborated in great detail in last week’s column, IMF’s programmes & tax reforms, Daily Times, July 25, 2021 that can be read by all who matter in the land and want to put Pakistan back on the road to prosperity by empowering the have-nots and taxing the rich and mighty rather than giving them unprecedented asset-whitening schemes, amnesties, concessions, waivers and tax-free benefits all documented in Unconstitutional asset-whitening schemes & amnesties, Surkhyian, January 7, 2021, Budget 2021: Taxes, Inflation Growth & IMF, Surkhyian, May 23, 2021 and Agenda for tax reforms, Surkhyian, May 18, 2021.
Dr. Ikramul Haq, Advocate Supreme Court, specialises in constitutional, corporate, media, IT, intellectual property, arbitration and international tax laws. He established Huzaima & Ikram in 1996 and is presently its chief partner as well as partner in Huzaima Ikram & Ijaz. He studied journalism, English literature and law. He is Chief Editor of Taxation. He is country editor and correspondent of International Bureau of Fiscal Documentation (IBFD) and member of International Fiscal Association (IFA). He isVisiting Faculty at Lahore University of Management Sciences (LUMS) and member Advisory Board and Visiting Senior Fellow of Pakistan Institute of Development Economics (PIDE).
He has coauthored with Huzaima Bukhari many books that include Tax Reforms in Pakistan: Historic & Critical Review, Towards Flat, Low-rate, Broad and Predictable Taxes (revised & Expanded Edition, Pakistan: Enigma of Taxation, Towards Flat, Low-rate, Broad and Predictable Taxes (revised/enlarged edition of December 2020), Law & Practice of Income Tax, Law , Practice of Sales Tax, Law and Practice of Corporate Law, Law & Practice of Federal Excise, Law & Practice of Sales Tax on Services, Federal Tax Laws of Pakistan, Provincial Tax Laws, Practical Handbook of Income Tax, Tax Laws of Pakistan, Principles of Income Tax with Glossary andMaster Tax Guide, Income Tax Digest 1886-2011 (with judicial analysis).
The recent publication, coauthored with Abdul Rauf Shakoori and Huzaima Bukhari is Pakistan Tackling FATF: Challenges & Solutions
available at: https://www.amazon.com/dp/B08RXH8W46
He is author of Commentary on Avoidance of Double Taxation Agreements signed by Pakistan, Pakistan: From Hash to Heroin, its sequelPakistan: Drug-trap to Debt-trap and Practical Handbook of Income Tax. He regularly writes columns for many Pakistani newspapers and international journals and has contributed over 2500 articles on a variety of issues of public interest, printed in various journals, magazines and newspapers at home and abroad.