OFFING ASSET DECLARATION SCHEME: 2018 VERSUS 2019
As per media reports, Federal Government is planning to announce an amnesty scheme for
declaration of undeclared Income, Undeclared Assets etc. before federal budget 2019-20. Certain
slides of the proposed amnesty scheme were also shared on media channels and social media.
Based on them, a brief comparison of the proposed amnesty scheme with that of scheme
introduced in 2018 is as under:
Description
Benami Assets
Undeclared Sales / Production
in Sales Tax / FED
Undisclosed Expenditure
Tax Demands subject
litigations in court
Tax Return Filing
Cash declaration
Gold Declarations
Bank Credits
Valuations
 Bank Accounts
 Open Plots, Land and Flats
 Super structure
 Motor Vehicles
 Gold
 Foreign Assets
Timeline
Tax Rates
 Benami Assets
 Foreign Liquid Assets
repatriated
 Credit entries in own bank
accounts
 Credit entries in benami
bank accounts
 Undisclosed Sales
 Other Assets
Repatriation
Amnesty Scheme 2018 Amnesty Scheme 2019
Not covered Covered
Not Covered Covered
Not Covered Covered
Assets with respect to which
to Tax demands on assets subject to
proceedings were pending in
litigation in courts are covered
court of law were not covered
Tax Return was not required
Tax return of Tax Year 2018 is
to be revised and effect of
required/allowed to be revised to
declaration was required to be
incorporate the declarations made
incorporated in next Tax Year
There is a condition to deposit the
No conditions
cash declared in bank accounts
There will be a limit on gold
No Conditions
declarations up to Rs. 5 million
Only closing balance of bank
Bank credit entries will also be
account was required to be
allowed to be declared
declared
Closing Balance Credit entries of last five years
Cost or FBR rate, whichever is Cost or FBR rate, whichever is
higher higher
Rs. 400 per square feet Rs. 1,500 per square feet
Allowance of depreciation was Cost incurred till original
allowed for used vehicle registration
Rs. 4,000 per gram Rs. 5,000 per gram
As per declarant Values will be as prescribed
10th April 2018 to 31st July
15th April 2019 till 30th June 2019
2018
N/A 10%
2% 5%
1% of total credit entries for five
N/A years or 10% of peak credit
entries whichever is higher
2% of total credit entries for five
N/A years or 10% of peak credit
entries whichever is higher
N/A 3% of sales
5% 7.5%
Repatriation of foreign assets Repatriation of foreign assets is
was optional mandatory
POINTS TO PONDER:
 The FBR values of land, open plots should be brought up to real market values. Unless the gap
between FBR market values and FBR values is not narrowed, the true benefits of
documentation are not possible.

 Tax on credit entries is in nature of turnover tax. An explanation will be required with respect
to applicability of sales tax or Federal excise Tax on such declarations.

 Undeclared sales are allowed to be declared by paying sales tax at 3%. As a result of such
declaration of sales, income will also be revised, however, no window to adjust/incorporate
such revised income is provided.

 Companies are also allowed to avail the scheme and are allowed to revise their balance sheets
to incorporate the declarations. However, there will be complications for auditors of such
companies who had already audited the Financial Statements of such companies and had
provided an unqualified opinion. There may also be litigations against such auditors by
shareholders who had relied upon such audit reports in past.