At a glance
- The test
- Income Tax Ordinance 2001, section 82: present in Pakistan 183 days or more in the tax year. Two other routes depend on facts, not days.
- Period
- Tax year, 1 July to 30 June, named for the year it ends in. Tax year 2027 runs from 1 July 2026 to 30 June 2027.
- What counts as a day
- Any part of a day in Pakistan is a whole day, including the days of arrival and departure (Income Tax Rules 2002, rule 14). Pure transit between two places outside Pakistan does not count.
The rule
Section 82(a): an individual is a resident individual for a tax year if present in Pakistan for a period, or periods adding up, of 183 days or more in the tax year.
Section 82(c): an employee or official of the Federal Government or a Provincial Government who is posted abroad in the tax year. This route does not depend on days.
Section 82(d), added by the Finance Act 2022: a citizen of Pakistan who is not present in any other country for more than 182 days during the tax year, or who is not a resident taxpayer of any other country. It stops applying to a citizen only when both are false.
Rule 14 (rules 2002): a part of a day counts as a whole day, including arrival and departure. Public holidays, leave and sick leave, days lost to a strike, lock-out or delayed supplies, and holidays spent in Pakistan around activity there count too. A day or part of a day spent solely in transit between two places outside Pakistan does not count.
A 120 days plus 365 days over four years condition applied to tax years 2020 and 2021 only and was later omitted. The threshold was 182 days before the Finance Act 2006 changed it to 183.
How Atrium counts it
Atrium counts any part of a day on a Pakistan Standard Time date as a day, arrival and departure both. This matches rule 14.
Atrium counts transit days even where rule 14 excludes transit between two foreign places. That can count more days than the law requires, so you are reminded earlier.
Atrium shows days left before 183 days in the 1 July to 30 June year. Where the government-employee or citizen route may apply, days do not decide it. Atrium shows your days and your longest stay in one other country, and leaves tax residence in that country to your adviser.
Atrium does not use the old 120 plus 365 condition.
What catches people out
- The condition is 183 days or more, so the 183rd day reaches it.
- Holidays, leave and sick days in Pakistan count in full. Only transit between two foreign places is carved out.
- The citizen route is not a day count. Few days in Pakistan do not remove it. It applies to a citizen unless the citizen was in some other country more than 182 days and is also a resident taxpayer of any other country.
- Passport stamps are the record. The FBR checks entry and exit stamps when it verifies a stay.
- The year runs July to June, so a visit in December and one in March fall in the same tax year.
Cases
FBR Circular No. 3 of 2023-24: passport stamps decide the stay for property sales
Federal Board of Revenue (official circular, not a court case) · 2023 · Circular No. 3 of 2023-24 (Income Tax), 15 August 2023 Source
The circular covers tax on deemed income from immovable property under section 7E, which applies to resident persons under section 82. A non-resident individual selling property must give the transferring authority a form, a passport copy and a list of entries and exits from the passport stamps. The authority must make sure the person's stay in Pakistan is under 183 days in each tax year claimed, from tax year 2022 onwards.
The day count is checked against stamped entry and exit records. Keep your trip dates matched to your passport.
Worked example (illustrative): three visits to Karachi in tax year 2026
Daniel, a UK citizen based in Dubai, visits Pakistan three times in tax year 2026 (1 July 2025 to 30 June 2026). He is in Pakistan from 10 to 20 August 2025, from 20 December 2025 to 15 January 2026, and from 1 to 31 March 2026. Both end days count. That is 11 + 27 + 31 = 69 days, so 114 days are left before 183.
Counting arrival and departure days in full is why short visits add up faster than they appear.
Sources
- Income Tax Ordinance 2001, sections 74 and 82, FBR consolidated text
- Income Tax Rules 2002, rule 14, FBR consolidated text
- FBR Circular No. 3 of 2023-24 (Income Tax)
Based on the sources above, last reviewed on 2026-10-04. Educational content, not tax advice. Atrium counts days; whether those days make you resident is for you and your adviser to decide.