The First Reading — No. 3

The third number of The First Reading opens the new fiscal year. The Finance Act has taken effect, the withholding tables have changed overnight, and six months of enforcement practice are now on the record. Ten developments, one paragraph each, one long read. Positions are stated as of July 1, 2026; anything not confirmed against the instrument as issued is bracketed for the reviewing lawyer.

1. Read the Finance Act, not the bill

The Finance Act 2026 took effect today [ACT AS PASSED, INCLUDING COMMITTEE-STAGE CHANGES, TO BE VERIFIED]. Every year, measures announced in June differ from what receives assent, and every year someone models a transaction on the bill. Before acting on any budget summary, have counsel confirm the enacted text of the provisions that matter to you — rates, super tax, withholding, and any new documentation or integration requirements.

2. July 1 resets the compliance machinery

The new fiscal year changes withholding rates, refreshes the active taxpayers list consequences, and advances the FBR's electronic-invoicing integration deadlines for registered persons [CURRENT PHASE AND DEADLINES TO BE VERIFIED]. Finance teams should reissue the withholding matrix to accounts payable today, not at the first audit query. Non-integration and non-filing penalties are the cheapest enforcement actions the FBR runs, which is why it runs them.

3. The digital tax on foreign vendors is a year old

The levy on digitally ordered goods and services supplied from abroad, enacted alongside the Finance Act 2025 [TITLE, RATE AND SCOPE OF THE INSTRUMENT TO BE VERIFIED], has now been in force for a year. Pakistani businesses that pay foreign platforms — advertising, software, cloud — are the collection point in most structures. If your payables process has not been mapped against it, do that this quarter, before the first-year audits begin.

4. The State Bank's half-year in one line

Through the first half of 2026 the SBP continued easing the operational side of the exchange regime by circular — import payments, exporter retention, repatriation processing [H1 2026 CIRCULARS TO BE VERIFIED] — while the Foreign Exchange Manual remains the binding text. For boards of foreign-invested companies, the July task is annual: reconcile the register of foreign investment with the authorised dealer's records so the next dividend faces no documentary surprise.

5. NAB at the half year

Accountability practice has settled into the post-restoration pattern: fewer, larger references above the Rs 500 million threshold, and continued transfers of smaller matters to other forums [HALF-YEAR FIGURES TO BE VERIFIED]. Two constants deserve repeating. A call-up notice is the beginning of the defence, not a formality. And a plea bargain under section 25 of the Ordinance carries statutory consequences, including disqualification from office, that must be priced before it is signed.

6. PECA's tribunals meet the high courts

Prosecutions under the amended PECA, including the false-information offence, have continued alongside interim orders from the high courts in the pending constitutional challenges [STATUS OF PETITIONS AND ANY INTERIM ORDERS TO BE VERIFIED]. The operating assumption for companies is unchanged from our first number: online-content disputes are criminal-law events. Preserve everything, respond through counsel, and do not let a communications team answer an NCCIA notice.

7. The constitutional forum question is still open

Challenges touching the Twenty-Sixth and Twenty-Seventh Amendments remain on the docket [HEARING STATUS AND FORUM TO BE VERIFIED], and with them a degree of uncertainty about where constitutional questions are finally decided. For pending writ petitions with a constitutional element, ask counsel a specific question: if the forum architecture shifts mid-case, what happens to this petition? The answer should be in writing in the file.

8. Competition enforcement at the half year

The CCP's first half held to the recent pattern: cartel inquiries in concentrated commodity markets and a steady line of deceptive-marketing orders, with digital advertising an increasing share [H1 2026 ORDERS TO BE VERIFIED]. The deceptive-marketing docket deserves board attention because it reaches routine conduct — claims in packaging, influencer promotions without disclosure, comparative advertising. Marketing sign-off should include a competition-law check, in writing.

9. Electronic evidence is now ordinary evidence

Courts continue to receive electronic records, video-link testimony and device-derived material under the Qanun-e-Shahadat Order 1984 as modernised [CURRENT PROVISIONS AND PRACTICE DIRECTIONS TO BE VERIFIED], and the contests are about authenticity and chain of custody, not admissibility in principle. The corporate consequence: how your organisation preserves emails, chat records and CCTV today determines what it can prove in three years. Retention policies are evidence policies.

10. Benami exposure has not gone away

The Benami Transactions (Prohibition) Act 2017 remains on the books, its adjudication machinery active in phases [CURRENT STATE OF ADJUDICATING AUTHORITIES AND ZONES TO BE VERIFIED], and benami allegations increasingly travel with NAB and AML proceedings rather than alone. Any structure where legal and beneficial ownership diverge — family holdings, employee nominees, parked shares — should be reviewed against the Act before a regulator does the reviewing.

The long read

Read the Supreme Court's decision in Ishtiaq Ahmed Mirza on audio and video evidence [CITATION — TO BE VERIFIED; REPORTED CIRCA 2019]. It set out how Pakistani courts test the genuineness of electronic recordings — authentication, forensic proof, the danger of edited material — years before the NCCIA existed. In a year when device seizures and chat exports drive both prosecutions and defences, it is the foundation document, and it is short.