Yes. Taxpayers are entitled to arrange their affairs within the law, choosing between lawful options such as equity or debt, direct or indirect ownership, and share or asset sales. The law does not permit evasion, false documentation or arrangements lacking the substance they claim. The Income Tax Act 2023 gives the tax authorities tools to examine transfer pricing and the real nature of transactions. Good tax structuring therefore rests on genuine commercial purpose, accurate documents and full compliance with filing obligations, including clarifying uncertain positions with the authority, and we advise only on structures meeting those standards.

There is no single right answer. An intermediate holding company may reduce withholding on dividends, interest or royalties if a treaty applies and the company is genuinely resident and the beneficial owner of the income. It may also simplify future exits. But it adds cost, substance requirements and reporting, and Bangladesh's treaty network does not cover every hub on favourable terms. The investor's home country rules matter too. We compare direct and indirect options for the specific investment, working with foreign counsel, before any company is formed or any share capital is injected. Costs must be weighed carefully.

The Finance Act 2026 reduced withholding on interest paid to non-residents from 20% to 10%. For groups funding Bangladeshi subsidiaries with shareholder loans, and for borrowers using offshore lenders, this lowers the cost of debt and of gross-up clauses. It does not remove the need for regulatory approval of foreign borrowing, arm's length pricing or proper reporting to Bangladesh Bank. Treaty rates may still be lower in some cases. We review existing facilities and new proposals to decide whether the change justifies refinancing or a different debt and equity balance. Loan terms on gross-up and prepayment should be checked first.

They can be, if the services or rights are genuine, priced at arm's length, properly documented and paid in accordance with the law. Withholding tax and VAT may apply to the payments, and remittance abroad is subject to foreign exchange rules, including Bangladesh Bank requirements for certain categories of fees. The tax authorities often question service charges that lack evidence of what was actually provided. We draft and review the agreements, coordinate transfer pricing support and prepare the evidence file, so that deduction, remittance and any later audit are handled consistently. Evidence must be contemporaneous where possible.

A sale of shares in a Bangladeshi company by a non-resident can give rise to capital gains tax in Bangladesh, subject to any applicable treaty relief, and the buyer or the company may have withholding or reporting obligations. Transfers to or from non-residents also need to comply with Bangladesh Bank rules on valuation and remittance, and listed shares are treated differently from unlisted ones. The tax position should be settled before signing, since it affects price and the conditions to closing. We advise sellers and buyers on the tax structuring of the exit and on repatriating the sale proceeds.

Often the cost can be reduced, though rarely eliminated. Moving property or businesses from individuals or partnerships into companies, merging group companies or separating businesses for different heirs can trigger capital gains tax, stamp duty, registration fees and source tax. The sequence, the method of transfer, valuation and any available exemptions all affect the total. A court-sanctioned scheme of amalgamation may be more efficient than a series of separate transfers in some cases. We model the options with the family's accountants and recommend a lawful route that fits succession and governance goals. Timing matters a great deal.

Transfer pricing rules require transactions between associated enterprises to be priced as independent parties would price them. Any structure involving intra-group sales, services, royalties, loans or guarantees must therefore be supported by a pricing analysis and documentation. The Income Tax Act 2023 requires certain taxpayers to file statements of international transactions and keep supporting records. A structure that shifts profit without supporting pricing is unlikely to survive an audit. We integrate transfer pricing into the design from the outset and work with economists or accountants where a benchmarking study is needed. Documentation should be refreshed annually.

Respond promptly, accurately and with evidence. Gather the agreements, board minutes, transfer pricing documents and correspondence that show the commercial purpose and substance of the structure, and avoid informal explanations that may later be used against the company. If an assessment or demand is issued, there are deadlines for objection and appeal, and missing them can be costly. Alternative dispute resolution may be available in some cases. We assess the merits, prepare written submissions and represent the business before the tax authorities, the tribunal and, where appropriate, the High Court Division. Records should be preserved at once.