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SHIRAZ KHAN
shiraz.shirazahmad@gmail.com

Assalamoalaikum to all
I am having a confusion regarding rules framed by FBR for group taxation. Rule 231-D (4) of income tax rules incorporated vide SRO 392(1)2009 states that;

The holding company as well as each subsidiary company shall furnish a certificate issued by the Securities and Exchange Commission of Pakistan verifying that the company has been complying with the Code of Corporate Governance as notified from time to time by the SECP.

Whereas amendment in Group companies regulation 2008 vide SRO 780(1)2009 dated 07 september 2009 has incorporated in Regulation 7 (i) the words 'wherever applicable' after the word 'Governance' which clearly suggests that it is not applicable on unlisted companies. But FBR's rules make it mandatory for unlisted companies as well. Isn't it an anomaly in these rules? Please if anyone could explain i would be grateful. 

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