Exactly how Section 236C and 236K rates hit your deal

What changed for FY27: 236C/236K at the registry (rates to be confirmed)

On a Rs 3.00 crore home, your federal withholdings can swing by several lacs depending on filer status and which valuation table (FBR vs DC) your registrar uses. That is the crux of Section 236C (seller) and 236K (buyer) in FY27.

FY27 vs FY26 — what the Finance Act says, and what still awaits notification: - Tax base (unchanged in the Act): Both sections continue to apply on the higher of your declared consideration versus the applicable official valuation used locally. See Income Tax Ordinance, 2001, sections 236C and 236K as amended by the Finance Act, 2026 (Gazette of Pakistan, 30 June 2026). Implementation varies by tehsil based on which valuation table the registrar enforces for federal and provincial heads — verify locally and get the written order they’re following. - Structure (Act text stays flat, not slabbed): The Finance Act, 2026 did not introduce value slabs for 236C/236K in the Ordinance text; the regime remains flat-rate withholding at transfer. Final percentages for FY27 are set via FBR notification (SRO) — see the “rates” note below. - Filer vs non‑filer differential (retained in law): The Income Tax Ordinance continues to distinguish filers vs non‑filers for these advance taxes. The exact FY27 percentages and any spread between filer and non‑filer will be those notified by FBR via the FY27 SRO for sections 236C and 236K. Keep the SRO number/date on your file once issued.

Here’s the clean version to work with while rates are being finalized:

• Both 236C (seller‑side) and 236K (buyer‑side) are collected at transfer on the higher of your declared consideration versus the official valuation used locally — in many tehsils that’s the DC (Deputy Commissioner) table for registry work, while FBR valuation tables are often referenced for federal heads. Practices can differ by district; ask your sub‑registrar which table applies to each head in your tehsil and note the written order/circular number they are enforcing.

• FY27 236C/236K rates: Treat this as a pre‑notification checklist. As of 30 Jul 2026, the FY27 percentages for Sections 236C (seller) and 236K (buyer) require the final FBR SRO to be effective. Do not plug rates from past years into current deals. Get the notified FY27 filer/non‑filer rates from the latest FBR SRO or your sub‑registrar before you sign tokens or submit challans.

• Who pays what: 236C is deducted from the seller’s proceeds right at transfer; 236K is paid by the buyer upfront to enable registration/transfer. These are advance taxes — filers can adjust them against their annual tax liability when filing returns (keep your CPR/challan).

Two practical notes I use on my own deal sheets: 1) Write “tax base = higher of price vs FBR/DC” in the agreement; attach a dated print of the valuation table you’re using. 2) Model both filer and non‑filer outcomes. I’ve seen a buyer slip off the ATL mid‑August and add Rs 20–30 lac to the closing stack on a mid‑range Karachi house.

Tools (one place to bookmark for closing): - [Stamp duty & tax calculator] for buyer/seller items collected at registry. - [Marla/kanal unit converter] for area sanity checks. - [Affordability calculator] and [Mortgage calculator] to test budgets. - Everything in one place: [Property tools hub].

Exemptions and edge cases at the registry (FY27)

236C/236K are “flat at registry” only for standard consideration‑based transfers. Several common carve‑outs can change, reduce or disapply these withholdings. Always tag your paperwork to the clause being applied and keep the circular/SRO on file.

Typical cases to check on your file (verify against the FY27 law/SRO actually in force in your tehsil): - Inheritance/succession, court‑sanctioned mutations and family settlements: Transfers without consideration may fall outside the charging scope of 236K and can be treated differently under 236C. Confirm under the Income Tax Ordinance, 2001, sections 236C/236K (as amended by Finance Act, 2026) and your local registry practice. - Gifts (hiba) without consideration between close family: Often treated as non‑consideration transfers for federal advance tax purposes; documentary proof and relationship evidence are typically required at registry. - First transfer by a developer to original allottees: In some schemes/periods, this has been exempted or treated separately via specific notifications. Ask the developer/society and cite the exact FBR SRO (FY27) if an exemption applies. - Government‑side transfers and compulsory acquisition: Transfers to/from government bodies or under acquisition orders are frequently carved out or handled under separate instructions. The sub‑registrar should reference the relevant notification on your challan. - Builder/allottee adjustments (swap, consolidation, re‑allotment within the same scheme): These can be processed under scheme‑specific directions; the treatment of 236C/236K may differ from an arm’s‑length sale.

Documentation to attach: the clause you’re invoking (s236C/s236K), the Finance Act year (2026), any applicable FY27 SRO/circular number, and the society/developer letter if it’s a scheme‑specific first transfer. If your case is unusual, get a one‑page ruling/endorsement from the sub‑registrar before you pay.

Deal-sheet walkthrough: who pays what on a standard file

Most closings in Pakistan still come down to two columns on a single page — buyer’s cash at closing and seller’s net. Spell them out to avoid friction at transfer.

Buyer cash at closing (typical components): - Token/baiana already paid at agreement stage (often 1–4% of price, netted off at closing). - Remaining sale price. - 236K buyer advance tax (apply the notified FY27 filer/non‑filer rate) on the higher of declared price vs FBR/DC value. - Provincial levies: stamp duty, CVT (where applicable as of FY27; verify your province’s current CVT), registration fee. - Society/TMA transfer fee if a private scheme is handling the mutation (often 0.5–1% in gated developments; check your society’s schedule). - Misc. verification/letter charges (Rs 5,000–50,000 depending on scheme).

Seller net proceeds (typical deductions): - Gross sale price. - Minus 236C seller advance tax (apply the notified FY27 filer/non‑filer rate) on the higher valuation base. - Minus society transfer/verification charges (if seller‑side per your MoU). - Minus any agent commission (1–2% is common but negotiable; some markets split buyer/seller commission). - Minus pending utility or dues if you agreed to clear them pre‑transfer.

Filer vs non‑filer scenarios to model side‑by‑side: - Ask your agent/deed writer to print both — filers typically sit lower; non‑filers are materially higher. If a party’s ATL status might change before registry, write a contingency right into the MoU: “If ATL status changes as of registry date, withholdings will be recomputed and either (a) the baiana adjusts by Rs X to compensate, or (b) the party who loses ATL status bears the incremental withholding.” That one line has saved clients of mine from last‑minute blowups.

Worked templates: Rs 1–5 crore homes (plug FY27 notified rates)

Important: The templates below show the mechanics only. Insert the notified FY27 percentages for 236C/236K and your province’s current levies before you wire funds.

Quick admin (dated 30 Jul 2026): Check ATL at https://e.fbr.gov.pk/esbn/Verification#ATLSearch and the applicable valuation table at https://www.fbr.gov.pk/valuation-tables. ATL status is effective as of the registry date; verify on the morning of transfer at fbr.gov.pk.

Notation for all four examples: - rK_filer, rK_nonfiler = notified FY27 percentages for 236K (buyer). - rC_filer, rC_nonfiler = notified FY27 percentages for 236C (seller). - Base = higher of declared price vs the valuation table used for federal heads in your tehsil (confirm if that’s FBR or DC at your office). - Add stamp duty/CVT/registration per your province’s schedule, and society transfer fee per your scheme.

Rs 1.00 crore example (base equals price)

Assume your declared price equals the official valuation base (no uplift from FBR/DC). Then:

• 236K (buyer, filer) = rK_filer × Rs 1,00,00,000.
• 236C (seller, filer) = rC_filer × Rs 1,00,00,000.

Non‑filer variant: - 236K (buyer, non‑filer) = rK_nonfiler × Rs 1,00,00,000. - 236C (seller, non‑filer) = rC_nonfiler × Rs 1,00,00,000.

Buyer’s cash stack at registry: - Sale price - + 236K (computed above) - + provincial levies (stamp/CVT/registration per current schedule) - + society/TMA fees (per schedule) - − baiana already paid

Seller’s net (before commission/dues): - Sale price − 236C (computed above)

Rs 2.50 crore example (price higher than valuation table)

Assume Islamabad flat where your agreed price is higher than the official valuation. Declared price = Rs 2,50,00,000; FBR/DC value = Rs 2,30,00,000. Taxes compute off Rs 2.50 crore (the higher base).

Filer case: - 236K (buyer) = rK_filer × Rs 2,50,00,000. - 236C (seller) = rC_filer × Rs 2,50,00,000.

Provincial levies will also apply on Rs 2.50 crore (check your province’s current stamp/CVT/registration schedule). Higher‑of cuts both ways: if your price is above the table, your tax base is your price.

Rs 3.00 crore example (valuation table higher than price)

Assume Lahore file where the official valuation for federal heads is 10% higher than your agreed price (common in some tehsils). Declared price = Rs 3,00,00,000; valuation = Rs 3,30,00,000. Taxes compute off Rs 3.30 crore (the higher base).

Filer case: - 236K (buyer) = rK_filer × Rs 3,30,00,000. - 236C (seller) = rC_filer × Rs 3,30,00,000.

Buyer’s other levies (computed on the applicable base per your tehsil/province): - Stamp duty, CVT, registration, society transfer fee (insert current‑year percentages/ceiling as per schedule).

Notice the kicker: even though you “got a deal” at Rs 3.00 crore, your withholdings rise off the Rs 3.30 crore valuation. Under‑invoicing doesn’t help if the table is higher.

Rs 5.00 crore example (contrast filer vs non‑filer)

Assume a Karachi bungalow transacting at Rs 5.00 crore, and suppose the official valuation base equals price.

• Filer buyer: 236K = rK_filer × Rs 5,00,00,000.
• Non‑filer buyer: 236K = rK_nonfiler × Rs 5,00,00,000.
• Filer seller: 236C = rC_filer × Rs 5,00,00,000.
• Non‑filer seller: 236C = rC_nonfiler × Rs 5,00,00,000.

Layer provincial levies and society fee on top (computed on the base your office uses for each head). On high‑ticket deals, some societies cap their transfer fee at a rupee ceiling; others keep it as a percentage. Verify the actual schedule to avoid a multi‑lac surprise.

Five decisions to make before you lock the baiana

1. Write down who bears 236K and 236C. Market norm: buyer pays 236K; seller bears 236C. If you deviate (say, “seller to bear both”), adjust the price and the token amount accordingly so cash at closing still lines up.

1. Fix the tax base in writing. Use the phrase “taxes on higher of price vs FBR/DC value” and attach the exact valuation page you’re using, with the date. I staple that print to the MoU — a mid‑month update in the table shouldn’t derail your budget.

1. Confirm filer status cut‑off. Use FBR ATL status as of the registry date. State it in the MoU and add a contingency if either party drops off ATL. Model both outcomes in rupees and keep the delta visible.

1. Agree on society/TMA charges. Many disputes are not about the headline price but a Rs 50,000–1,50,000 fight over NOC, verification or urgent transfer fees. List them.

1. Decide how agent commission is paid. Split? One side only? On gross or net of taxes? Write it plainly with the rupee amounts so it isn’t debated at the window.

If you need a second set of eyes on the paperwork, you can [Find an agent] who works your target society, or browse [Real estate agencies] and pick firms with recent transfers in that precinct.

Common mistakes that add lacs to closing costs

• Thinking under‑invoicing shrinks federal withholdings. It doesn’t if the official valuation is higher — 236C/236K ride the higher of declared vs FBR/DC value. A client of mine in DHA Phase 8 Karachi shaved Rs 20 lac off the declared price; the DC table was higher anyway, so they saved zero on 236K and earned a side of stress.

• Ignoring provincial levies. Stamp duty, CVT and registration vary by province and can add real money on top of federal withholdings. For a Rs 3.00 crore flat, that can land in the multi‑lac range. Check the current‑year schedule for your tehsil, and budget it in writing.

• Treating advance tax as a dead cost. If you’re a filer, 236C/236K are adjustable against your annual income tax. Keep CPRs and challans tidy — your accountant will claim them. I put scanned copies in the same folder as the registry deed.

• Forgetting society transfer fees. Gated schemes often charge 0.5–1% to process a transfer or letter. That’s Rs 50,000–1,00,000 per crore of value.

• Misjudging the valuation table used locally. Some offices compute provincial levies off DC tables and federal heads off FBR tables; others align on one table. Ask your deed writer which table your sub‑registrar enforces and note the circular/order number; don’t guess.

While you’re budgeting, sanity‑check your price expectations with recent [Sold prices] in your area and our [Property price index] for trend context.

Quick checklist you can run today

• Pull today’s valuation for your plot/flat at https://www.fbr.gov.pk/valuation-tables (by marla/kanal/sq ft) and write down the higher number versus your negotiated price. If you don’t know the exact area in sq ft, convert it before you calculate.

• Do not assume last year’s 236C/236K percentages. Confirm the FY27 notified filer/non‑filer rates (FBR SRO) and compute both on the higher base. If the SRO is still pending, prepare a placeholder line item and a price‑adjustment clause in the MoU so you’re not exposed to a late‑cycle change.

• Add provincial levies — stamp duty, CVT and registration — per your province’s current schedule. Layer in society transfer fee (some schemes cap, others charge a percentage) to estimate the buyer’s total cash. For the seller, subtract 236C and any commission or dues to get a realistic net. Sense‑check against the Rs 1, 2.5, 3 and 5 crore templates above.

• Verify ATL status on the morning of registry at https://e.fbr.gov.pk/esbn/Verification#ATLSearch and print a screenshot for your file. If ATL status might flip, have a written contingency in the MoU.

• If you’re still negotiating price, build a full “cash at registry” stack so both sides see the rupee outcome after taxes and fees. For financed buyers, add the bank’s disbursement timing and any lien/NOC charges into the closing calendar.

Set up your FY27 closing file now

A smooth registry is won days before transfer. Do three things this week: (1) print and date the valuation table page you’ll use; (2) model both filer and non‑filer stacks for 236C/236K so no one is surprised; (3) clip CPR/challan checklists to your MoU. If you’re hunting or listing this season, keep your calculators and checklists in one folder so they’re ready for the next deal.