Transfer Pricing in Bangladesh

by Barrister Tahmidur Rahman | Sep 10, 2026

Corporate & FinanceArm's length pricing, documented and defended8 min read

Transfer Pricing in Bangladesh

Practical transfer pricing advice in Bangladesh for multinational groups and Bangladeshi companies with foreign affiliates: intra-group agreements, arm's length policies, documentation and statements under the Income Tax Act 2023, alignment with customs and VAT, and the defence of NBR audits, adjustments and appeals.

Overview

Transfer pricing rules for Bangladesh-connected groups

Transfer pricing in Bangladesh governs how a company prices its dealings with associated enterprises abroad: purchases of raw materials, sales of finished goods, royalties for brands and technology, management and IT service charges, intra-group loans and guarantees. The rules, first introduced into the old Income Tax Ordinance 1984 and carried into the Income Tax Act 2023, require these international transactions to be priced at arm's length, as independent parties would price them. We advise subsidiaries of foreign groups, Bangladeshi groups with overseas affiliates and investors planning new structures, as part of our corporate and tax practice in Bangladesh.

The obligations have three layers. First, the price itself must be consistent with the arm's length principle, determined using one of the recognised methods, such as the comparable uncontrolled price method, resale price, cost plus, profit split or transactional net margin methods. Second, taxpayers with international transactions must keep prescribed information and documents showing how the price was set. Third, they must file a statement of international transactions with the return and, in some cases, a report from an accountant. Failure at any layer can lead to adjustments, penalties and long disputes with the National Board of Revenue.

Transfer pricing audits in Bangladesh tend to focus on familiar targets. Royalties and technical fees paid to a foreign parent, management charges without clear evidence of services, the margins earned by contract manufacturers and distributors, and interest on shareholder loans attract the most attention. The tax authorities may also compare the price declared for customs purposes with the price used for income tax, so inconsistency between customs valuation and transfer pricing files is a frequent problem. Clear intercompany agreements, contemporaneous evidence of services and a coherent pricing policy across all taxes remain the best protection a business can have.

Foreign exchange rules add a further dimension. Remittances of royalties, technical assistance fees and service charges are subject to Bangladesh Bank requirements and, for some categories, to limits or approvals, while foreign loans need regulatory scrutiny that since 23 August 2026 involves Invest Bangladesh rather than BIDA. A payment that is correctly priced for transfer pricing purposes may still be blocked if the remittance requirements are not met. We review pricing, documentation and remittance together, so that an intra-group arrangement is deductible, permitted and payable without later complications for the local company or its foreign parent.

When an adjustment is proposed, the response must be quick and well evidenced. The statutory routes include objection, appeal to the commissioner and the tribunal, and reference to the High Court Division on questions of law, and alternative dispute resolution may be available. Where a double tax treaty applies, the mutual agreement procedure may help relieve double taxation. Our tax disputes team acts in these proceedings, working with economists and accountants on benchmarking. Our tax structuring lawyers help groups redesign arrangements so the same issue does not return in later years. Prevention is usually far cheaper.

01 · What we handle

Core workstreams

  • Transfer pricing policy design
  • Intercompany agreement drafting
  • Documentation and annual filings
  • Customs and VAT alignment
02 · How it runs

Four clear stages

  1. 01Map all group transactions
  2. 02Test the current pricing
  3. 03Document and file
  4. 04Defend and improve
03 · Start here

Talk to a partner

Consultations in Dhaka or by video. Scope, team and fees are agreed in writing first.

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How we help

How we help with transfer pricing

Workstream 01Corporate & Finance

Transfer pricing policy design

  • Map all group transactions
  • Test the current pricing
  • Document and file
  • Defend and improve
Workstream 02Corporate & Finance

Intercompany agreement drafting

  • Map all group transactions
  • Test the current pricing
  • Document and file
  • Defend and improve
Workstream 03Corporate & Finance

Documentation and annual filings

  • Map all group transactions
  • Test the current pricing
  • Document and file
  • Defend and improve
Workstream 04Corporate & Finance

Customs and VAT alignment

  • Map all group transactions
  • Test the current pricing
  • Document and file
  • Defend and improve
Workstream 05Corporate & Finance

Audits, adjustments and appeals

  • Map all group transactions
  • Test the current pricing
  • Document and file
  • Defend and improve
Workstream 06Corporate & Finance

Restructuring and new arrangements

  • Map all group transactions
  • Test the current pricing
  • Document and file
  • Defend and improve
01

Transfer pricing policy design

We help groups set a defensible pricing policy for each category of intra-group transaction, choose the most appropriate method, define the roles and risks of each entity, and record the policy in a form the Bangladeshi company can follow in practice. We coordinate with the group's global transfer pricing team so the local position is consistent with the group master file and with arrangements in other countries. The policy should reflect what the local team actually does, not only the group's global description of roles.

02

Intercompany agreement drafting

Many audits turn on the absence or weakness of written agreements. We draft and review distribution, manufacturing, licence, services, cost-sharing, loan and guarantee agreements between Bangladeshi companies and their foreign affiliates. Each agreement reflects the actual conduct of the parties, the pricing method and the evidence that will be kept, and is aligned with VAT, withholding and Bangladesh Bank remittance requirements. Old agreements are refreshed when the business changes.

03

Documentation and annual filings

We work with the client's accountants and transfer pricing economists to prepare the local documentation, statements of international transactions and supporting records required under the Income Tax Act 2023. We review benchmarking studies for legal consistency, check that the documents match the agreements and accounts, and set up an annual process so that information is collected as transactions occur rather than reconstructed later. Deadlines are diarised in advance.

04

Customs and VAT alignment

Transfer pricing adjustments can affect customs value and VAT on imports, and customs officials may look at year-end adjustments as evidence of undervaluation. We advise on aligning intra-group pricing for income tax, customs and VAT purposes, on the treatment of retrospective price adjustments, and on how to explain related-party pricing to customs authorities when goods are cleared at the port or land border. Consistent files reduce friction at clearance.

05

Audits, adjustments and appeals

When the National Board of Revenue opens a transfer pricing audit or proposes an adjustment, we review the issues, prepare written submissions, coordinate economic evidence and represent the company at hearings. If an assessment is made, we pursue objections and appeals before the commissioner and tribunal, and references or writ petitions before the High Court Division where questions of law or procedure arise. Settlement options are kept under review.

06

Restructuring and new arrangements

Business changes, such as converting a full-risk distributor into a limited-risk distributor, centralising procurement, introducing new royalties or moving functions between countries, raise transfer pricing questions in Bangladesh. We assess the local tax consequences before implementation, including any exit charges or re-characterisation risk, and design the agreements, approvals and documentation so the new arrangement is defensible from its first year. Board approvals and timing are planned as well.

RecognitionThe Legal 500Asia Pacific ranks Tahmidur Remura Wahid (TRW) Law Firm for dispute resolution in Bangladesh.
Cross-border reach6 jurisdictionsMatters coordinated with counsel in the UK, US, UAE, China, India and Singapore.
Bar and admissionsDhaka and LondonBarristers and advocates in Bangladesh, with a solicitor of England and Wales (non-practising).
HeadquartersDhakaHouse 410, Road 29, Mohakhali DOHS. Consultations in person or by video.
Who leads this work

Partner-led, on every matter.

Corporate & Finance matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.

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01

Which companies are subject to transfer pricing rules in Bangladesh?

The rules apply where a taxpayer enters into an international transaction with an associated enterprise, meaning a related party outside Bangladesh connected through ownership, control or certain other relationships defined in the law. Subsidiaries and branches of multinational groups are the obvious examples, but Bangladeshi groups with foreign subsidiaries or affiliates are also covered. The scope of associated enterprise is broader than simple majority ownership, so groups should check the definition carefully. We review the group's relationships and transactions to confirm which are within the rules and what documentation and filings are required each year.

02

What transfer pricing documentation must a Bangladeshi company keep and file?

The Income Tax Act 2023 requires taxpayers with international transactions to keep prescribed information and documents describing the group, the business, the transactions, the functions performed, assets used and risks assumed, the pricing method chosen and the comparable data relied on. A statement of international transactions must be filed with the return, and some taxpayers must also obtain an accountant's report. Thresholds and formats can change through the Finance Act and rules, so the current requirements should be checked every year. We help clients build documentation that is accurate, consistent and practical to maintain.

03

Are royalties and management fees paid abroad a transfer pricing risk?

Yes, they are among the most frequently challenged payments. The tax authorities often ask whether services were actually rendered, whether they duplicated work done locally, whether the Bangladeshi company benefited and whether the fee is commercially justified. Royalties are tested against the value of the brand or technology to the local market. Evidence such as service logs, reports, correspondence and cost allocations is essential. Remittance of these fees also requires compliance with Bangladesh Bank rules. We help companies document the benefit received and align the agreements, pricing and remittance paperwork before payments are made.

04

How do transfer pricing and customs valuation interact at the border?

Both regimes examine related-party prices, but from opposite directions. The income tax authorities may suspect that import prices from a parent are too high, reducing local profit, while customs may suspect they are too low, reducing duty. A year-end adjustment that lowers prices for income tax may be treated by customs as evidence of earlier overvaluation, or the reverse. Under the Customs Act 2023, related-party transactions may be examined to see whether the relationship influenced the price. We advise on a coherent approach so that the same pricing story can be explained consistently to both authorities.

05

What penalties apply for transfer pricing failures in Bangladesh?

The Income Tax Act 2023 provides for penalties for failing to keep documentation, failing to file the statement of international transactions, failing to furnish information when required, and for adjustments resulting from non-arm's length pricing, in addition to the tax and any interest on the adjusted amount. Exact amounts and conditions should be checked in the current law and the latest Finance Act. Penalties can often be reduced or avoided by timely compliance and cooperation. We review the client's exposure, advise on corrective filings and respond to penalty proceedings when they are initiated.

06

Can intra-group loans and guarantees create transfer pricing issues?

Yes. Interest on loans from a foreign parent or affiliate must be at an arm's length rate, considering the borrower's credit standing, the currency, the tenor and the security. Guarantee fees charged by a parent for supporting local borrowing are also tested. Foreign loans require regulatory scrutiny and reporting, and the Finance Act 2026 reduced withholding on interest paid to non-residents from 20% to 10%, which affects the after-tax cost. We review the loan terms, pricing evidence and approvals together, so that interest is deductible, the loan is properly approved and repayments can be remitted when due.

07

How long does a transfer pricing audit in Bangladesh take?

There is no fixed duration. A focused audit that is answered promptly with good documentation may conclude within a single assessment cycle, while disputes over benchmarking or the characterisation of a business can run through several levels of appeal over a number of years. The time limits for assessment and appeal under the Income Tax Act 2023 shape the timetable. We give clients a realistic view of likely stages after reviewing the notice and the documentation, and we manage the response to avoid procedural delays that weaken the company's position. Early engagement often shortens the process.

08

Can a double tax treaty help with a transfer pricing adjustment?

Where Bangladesh has a double tax treaty with the country of the associated enterprise, the treaty may provide a mutual agreement procedure through which the competent authorities of the two countries try to eliminate double taxation caused by an adjustment. Access depends on the treaty wording, time limits and the domestic procedures in each country, and the outcome is not guaranteed. The procedure can run in parallel with or after domestic remedies, depending on the case. We advise on whether to invoke it and coordinate with advisers in the other country on the request and supporting evidence.

How a matter runs

From first call to resolution.

  1. 01

    Map all group transactions

    We identify every international transaction with associated enterprises, the agreements in place, the cash flows and the current pricing, and highlight the arrangements most likely to attract scrutiny. Group charts, contracts and ledgers are reviewed together.

  2. 02

    Test the current pricing

    With the client's economists or accountants, we test pricing against the arm's length standard, review benchmarking, and recommend changes to policy, agreements or remittance practice where gaps appear. Our findings are then shared with the group tax team.

  3. 03

    Document and file

    We prepare or review the local documentation, statements of international transactions and supporting records, aligned with customs and VAT filings, and set up an annual compliance calendar. Each transfer pricing file is checked against the accounts before filing.

  4. 04

    Defend and improve

    If the NBR raises queries or proposes an adjustment, we respond, negotiate and litigate where necessary, then use the lessons to strengthen the following year's documentation and policy. Every lesson learned is fed back into the next annual cycle.

“Demonstrates an extraordinary command over both domestic litigation and international arbitration.”

The Legal 500 Asia Pacific, Bangladesh: Dispute resolution, client feedback

FAQ

Questions, answered.

Still unsure? Email info@trw.co with a short outline of the matter.

What is transfer pricing and why does it matter in Bangladesh?
Transfer pricing is the pricing of transactions between related companies in a group, such as sales of goods, services, royalties and loans. Tax law requires these prices to reflect what independent parties would agree in comparable circumstances, known as the arm's length principle. In Bangladesh, the rules apply mainly to international transactions between a taxpayer and its associated enterprises abroad, and are enforced by the National Board of Revenue. Getting it wrong can mean adjustments, interest and penalties.
Where are the transfer pricing rules in Bangladesh found?
The rules were introduced into the Income Tax Ordinance 1984 and now sit in the Income Tax Act 2023, supported by rules, forms and guidance issued by the National Board of Revenue. The annual Finance Acts may amend the provisions, thresholds or penalties. Double tax treaties also contain associated enterprise articles that are relevant when an adjustment leads to double taxation across two countries. We track amendments after each annual budget. Treaty wording varies by country.
Which transfer pricing methods are accepted by the NBR?
The law recognises the standard methods: comparable uncontrolled price, resale price, cost plus, profit split and transactional net margin, together with other methods where these cannot reasonably be applied. The most appropriate method depends on the transaction, the available data and the functions and risks of each party. The choice should be explained in the documentation and applied consistently from one year to the next. Changes of method should be explained and justified. The documentation should show why other methods were rejected, as authorities often ask for this reasoning.
Do small Bangladeshi companies need full transfer pricing documentation every year?
Any taxpayer with international transactions with associated enterprises is within the rules, but some filing obligations, such as the accountant's report, apply only above certain thresholds that are set and revised by law. Even below those thresholds, keeping basic agreements and pricing evidence is sensible, because the tax authorities can still question the price. We confirm the current thresholds and a proportionate level of documentation. Simple, consistent records are usually enough for smaller groups. A short memo recording why a transaction is small or low risk can help if it is later questioned.
Does transfer pricing apply to branches of foreign companies?
Yes. Dealings between a Bangladeshi branch and its head office or other group entities abroad, such as head office expense allocations, service charges and interest, raise transfer pricing and deductibility questions. Branch profits and remittances also have their own tax and foreign exchange rules. We review head office charges and allocation keys to make sure they are supportable and properly documented. Branch accounts should show how each charge was calculated and why. Remittances need matching bank documents.
Can we correct transfer pricing errors made in earlier tax years?
In some cases, a company can revise a return or make a voluntary disclosure within the time allowed, which may reduce penalties and show good faith. In others, the better course is to strengthen documentation and policy going forward while preparing to defend earlier years if they are audited. We assess the exposure, the time limits and the options before any corrective step is taken. Professional advice is essential before any disclosure is made to the authorities.
Is benchmarking data from other countries acceptable to the tax authorities?
Local comparable data for Bangladesh is often limited, so groups frequently rely on regional or international databases. The tax authorities may question the comparability of foreign data, so studies should explain why the comparables are appropriate and what adjustments have been made for differences in markets, functions and risks. We review benchmarking studies for consistency with the legal requirements and the facts. Studies should be refreshed regularly as market conditions change. Local data is used where reliable.
How can TRW help with a transfer pricing matter?
We draft and review intercompany agreements, check documentation for legal consistency, align pricing with customs and remittance rules, and represent companies in audits and appeals. To begin, send a short summary of the transactions or the notice received through our contact page or to info@trw.co. We will confirm scope and fees after a conflict check. Detailed documents should follow once engagement terms are agreed. We usually respond within a few working days. All fees are agreed in writing.

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