FBR: moving stock to your own warehouse needs no e-invoice, but must travel with a Stock Transfer Note

FBR: moving stock to your own warehouse needs no e-invoice, but must travel with a Stock Transfer Note

28 September 2026: Pakistan's Federal Board of Revenue (FBR) issued Sales Tax General Order No. 25 of 2026 on 28 September 2026. It settles a question that Pakistan's move to digital invoicing had left open: what document goods need when a manufacturer moves them from its own factory to its own warehouse.

The ruling

When goods move between a factory and a warehouse held under the same sales tax registration number (STRN), there is no change of ownership and no consideration, so the FBR says the movement is not a "supply" under the Sales Tax Act, 1990. No tax invoice is required, and the digital-invoicing rules for sending invoices through a licensed integrator or PRAL do not apply.

The movement must still be documented. Every consignment has to carry a Stock Transfer Note, in the format at Annexure-A of the order:

• generated before dispatch, sequentially numbered, and endorsed "Stock Transfer -- Not a Taxable Supply";
• with value recorded at cost, for inventory control only, and not styled or numbered like a tax invoice;
• kept with the goods throughout transit and produced on demand at any check-post;
• acknowledged by the warehouse on receipt, with both the warehouse and factory stock registers updated;
• kept at both ends, reconciled monthly against production and inventory records, and preserved for six years.

If the receiving warehouse has its own STRN, the movement is a taxable supply between two registered persons: a digital invoice through a licensed integrator or PRAL is mandatory and output tax is charged as normal. A Stock Transfer Note is not a substitute in that case.

Goods moving with neither a tax invoice nor a Stock Transfer Note are to be treated as prima facie undocumented, and risk detention in transit and being treated as clandestine removal on audit.

New limits on transit checks

The same order tells FBR field formations that officers must not demand a driver's CNIC or any document beyond the digital invoice or Stock Transfer Note; must not divert or detain vehicles at unauthorised premises; and must not physically check or unload goods in transit, except to verify printed retail prices on Third Schedule goods. A missing digital invoice is to be dealt with separately and is not a ground to detain goods on the road.

What to do

• Manufacturers should add the Stock Transfer Note, in the Annexure-A format, to their dispatch process for moves to their own warehouses, and train drivers and gate staff to carry it.
• ERP and e-invoicing vendors and integrators serving Pakistani manufacturers should add a non-fiscal stock-transfer document with its own numbering series, kept apart from tax invoices, and a monthly reconciliation report.
• Check the registration of each warehouse: a separately registered warehouse needs a digital invoice for every movement.

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Sources

• Federal Board of Revenue: Sales Tax General Order No. 25 of 2026, Movement of goods from factory to registered person’s own warehouse (PDF) - 28 September 2026
• Associated Press of Pakistan: KCCI welcomes FBR order on factory-to-warehouse stock transfers - 28 September 2026