SECP and FBR Compliances for No Business Private Limited Companies in Pakistan
— Even If No Business Activity & No Bank Account Exists
By Dawars Associates
Many entrepreneurs register a Private Limited Company in Pakistan but do not start operations immediately. In many cases, there is:
- No business activity
- No bank account
- No income
- No expenses
- No transactions
A common question we receive at Dawars Associates is:
“Since no work is done and no bank account is opened, do we still need to file SECP and FBR returns?”
The answer is:
✅ Yes — Compliance Is 100% Mandatory
Whether business has started or not, the company legally exists and must fulfill all statutory obligations.
1. SECP Mandatory Filings
a) Annual Return (Form A Form 9 & Form 19)
Every private limited company must file an annual return once every year, regardless of activity status.
b) Annual Financial Statements
Even a dormant company must prepare:
- Balance sheet
- Profit & Loss (zero activity)
- Auditor’s report (if applicable)
- Notes stating no business was conducted
c) Auditor Appointment
Most companies must appoint an external auditor every year, even with NIL transactions.
2. FBR Mandatory Filings
a) Income Tax Return
A company must file a tax return every year.
A NIL return must be filed showing:
- No business
- No income
- No expenses
b) Wealth Statement
A NIL wealth statement must also be submitted.
c) Sales Tax Return (If Registered)
If the company holds an STRN, monthly NIL returns are mandatory.
3. What If No Bank Account Is Opened?
Opening a bank account is not linked to compliance obligations.
Even without an account:
✔ The company is legally active
✔ Filings remain compulsory
✔ FBR and SECP expect annual submissions
Not filing can lead to penalties and notices.
4. Consequences of Not Filing
- Heavy SECP late fees
- FBR penalties
- Notices under sections 114, 118, 147, 122, 176
- Directors become non-filers
- Company may be declared inactive
- Risk of being struck off by SECP
5. Dawars Associates Compliance Services
We provide a complete Annual Compliance Package for inactive companies:
- SECP Annual Return
- Annual Financial Statements (NIL)
- Auditor Appointment
- FBR Income Tax Return
- NIL Wealth Statement
- Sales Tax NIL Return (if required)
📞 Contact us for smooth, penalty-free compliance.
🔗 Follow Dawars Associates for more updates on FBR regulations, tax compliance, and corporate services.
