VAT & Customs in Bangladesh

by Barrister Tahmidur Rahman | Sep 11, 2026

Corporate & FinanceIndirect tax, imports and border compliance9 min read

VAT & Customs in Bangladesh

VAT and customs advice in Bangladesh for manufacturers, importers, exporters, service providers and foreign suppliers: registration, monthly returns and deduction at source, input tax credit, tariff classification and valuation, bonded and duty-drawback regimes, audits, seizures, demands and appeals before the tribunal and the courts.

VAT & Customs in Bangladesh: VAT with TRW & Co
Matter planCorporate & Finance
  1. Diagnose the real issue
  2. Advise and correct promptly
  3. Engage the relevant authorities
  4. Resolve and prevent recurrence
Overview

VAT and customs rules businesses must get right

VAT and customs duty are often the largest taxes a Bangladeshi business pays, and the most procedural. VAT is governed by the Value Added Tax and Supplementary Duty Act 2012 and its rules, in force since 2019, with a standard rate and a range of reduced rates, exemptions and supplementary duties. Customs duty, regulatory duty and related charges at import fall under the Customs Act 2023, which replaced the Customs Act 1969, together with the annual tariff schedules in the Finance Act. We advise on both regimes as part of our corporate and tax practice in Bangladesh.

Registration is the starting point. A business making taxable supplies above the registration threshold must obtain a business identification number (BIN) and register for VAT, while smaller businesses may fall under turnover tax instead. Registered persons must issue Mushak invoices, keep purchase and sales records, file monthly returns through the online system and pay on time. Many buyers, including companies, banks and government bodies, must deduct tax at source from payments to suppliers, which creates its own compliance burden. Errors in invoices, credit notes or deduction certificates are among the most common causes of later demands from the revenue authorities.

Input tax credit is where VAT costs are won or lost. A registered business can generally set the tax paid on its inputs against the tax due on its own supplies, but only if the inputs are used for taxable supplies, the supporting invoices and import documents are valid, and the credit is claimed within the allowed period. Exempt or reduced-rate supplies, mixed businesses and imported services complicate the calculation. We review credit positions, apportionment methods and supplier documentation, and help businesses claim refunds where they consistently pay more on inputs than they collect on sales, as exporters often do.

At the border, the main questions are tariff classification, customs valuation, origin and eligibility for concessions. Classification under the Harmonized System decides the duty rate, and disputes often arise where products could fall within several headings. Valuation starts from the transaction value but may be adjusted for royalties, assists or the influence of a relationship between buyer and seller, which links customs to transfer pricing. Bonded warehouse licences, duty drawback and concessionary rates for capital machinery can reduce costs, but each has strict conditions. Our regulatory team also advises on C&F agent and authorised economic operator questions.

When the authorities question a position, the response must be prompt and well documented. Audits, show-cause notices, demands, seizures of goods and penalties can each be challenged through statutory procedures, including appeals to the commissioner and to the Customs, Excise and VAT Appellate Tribunal, and references or writ petitions in the High Court Division. Alternative dispute resolution may be available in some cases. Our dispute resolution lawyers handle these matters, working with the client's consultants and clearing agents. We focus on settling the immediate issue and on fixing the underlying process so that it does not recur.

01 · What we handle

Core workstreams

  • VAT registration and set-up
  • VAT compliance health checks
  • Tariff classification and valuation
  • Bonded, drawback and concession regimes
02 · How it runs

Four clear stages

  1. 01Diagnose the real issue
  2. 02Advise and correct promptly
  3. 03Engage the relevant authorities
  4. 04Resolve and prevent recurrence
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

Our VAT and customs work

Workstream 01Corporate & Finance

VAT registration and set-up

  • Diagnose the real issue
  • Advise and correct promptly
  • Engage the relevant authorities
  • Resolve and prevent recurrence
Workstream 02Corporate & Finance

VAT compliance health checks

  • Diagnose the real issue
  • Advise and correct promptly
  • Engage the relevant authorities
  • Resolve and prevent recurrence
Workstream 03Corporate & Finance

Tariff classification and valuation

  • Diagnose the real issue
  • Advise and correct promptly
  • Engage the relevant authorities
  • Resolve and prevent recurrence
Workstream 04Corporate & Finance

Bonded, drawback and concession regimes

  • Diagnose the real issue
  • Advise and correct promptly
  • Engage the relevant authorities
  • Resolve and prevent recurrence
Workstream 05Corporate & Finance

Contracts and pricing

  • Diagnose the real issue
  • Advise and correct promptly
  • Engage the relevant authorities
  • Resolve and prevent recurrence
Workstream 06Corporate & Finance

Audits, seizures and appeals

  • Diagnose the real issue
  • Advise and correct promptly
  • Engage the relevant authorities
  • Resolve and prevent recurrence
01

VAT registration and set-up

We advise new and expanding businesses on registration, central or branch registration, turnover tax, the treatment of each revenue stream, invoicing requirements and the online return system. For foreign suppliers of digital and other services to Bangladeshi customers, we explain when VAT applies, who must account for it and how deduction at source works, so that pricing and contracts reflect the real tax cost from the very first invoice.

02

VAT compliance health checks

We review invoices, credit and debit notes, deduction certificates, input tax credit claims, apportionment methods and monthly returns, then report the exposures we find and how to correct them. Health checks are particularly useful before an acquisition, after rapid growth or a change of accounting system, and when the business expects an audit or has received initial queries from its local commissionerate. Findings are ranked by risk and cost.

03

Tariff classification and valuation

We advise importers on Harmonized System classification, the duty consequences of each heading, customs valuation for related-party and royalty-bearing imports, and the documents needed to support declared values. Where classification or valuation is disputed, we prepare technical submissions and, where possible, seek clarification from the authorities before goods are shipped, reducing the risk of costly delays and demurrage at the port. Import VAT is checked too. Written clarifications from the authorities are kept on file to support later declarations.

04

Bonded, drawback and concession regimes

Export-oriented manufacturers rely on bonded warehouse licences, duty drawback and concessionary rates for capital machinery and inputs. We advise on eligibility, licence applications and renewals, entitlement calculations, record-keeping and audits, and on the consequences of selling bonded goods locally. We also review statutory regulatory orders granting exemptions, since their conditions are applied strictly by customs officials at clearance. VAT on local sales is reviewed separately. Audit files are kept ready.

05

Contracts and pricing

Indirect tax should be dealt with clearly in commercial contracts. We draft and review supply, distribution, services and construction contracts so that VAT, supplementary duty, deduction at source and customs costs are allocated clearly, invoices meet legal requirements, and prices adjust when rates change. In public procurement, we advise on how indirect tax is treated in tenders and in payments made by government buyers. VAT clauses are tested against invoicing.

06

Audits, seizures and appeals

We represent businesses in VAT audits, intelligence directorate investigations and customs inquiries, respond to show-cause notices and demands, and seek release of seized goods. If a dispute continues, we file appeals before the commissioner and the appellate tribunal, and references or writ petitions in the High Court Division where questions of law or jurisdiction arise, keeping the client's commercial priorities in view throughout. Settlement is always considered alongside appeal.

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.

Meet the firm →
01

When must a business register for VAT in Bangladesh?

A business must register when its turnover from taxable supplies exceeds the registration threshold set by law, while businesses below that level may be covered by turnover tax. Certain businesses must register regardless of turnover, including importers, exporters and some specified sectors. The thresholds and categories have changed through successive Finance Acts, so the current figures should be checked at the time of registration. Registration is made online and produces a BIN. We review the business model and advise on whether, when and how to register, including how branches should be treated. Late registration can attract penalties.

02

How does VAT deduction at source work for buyers and suppliers?

Specified buyers, including government bodies, banks, insurance companies, NGOs and many companies, must deduct tax from payments for certain supplies and deposit it with the treasury, giving the supplier a deduction certificate. The supplier then accounts for the amount deducted in its own return. Mismatches between the buyer's deduction and the supplier's return are a common audit issue, and buyers that fail to deduct can become liable themselves. We advise both buyers and suppliers on the rules, documentation and reconciliation needed to avoid duplicate payments, missing credits and penalty proceedings. Monthly matching of certificates to returns catches differences early.

03

Can we claim input tax credit on all our business purchases?

Not always. Input tax credit is generally available only for tax paid on inputs used to make taxable supplies, supported by valid Mushak invoices or import documents and claimed within the time allowed. Credit may be restricted for certain categories of purchase, for exempt supplies and for inputs used in both taxable and exempt activities, where apportionment is needed. Credit can also be disallowed if the supplier did not deposit the tax or the invoice is defective. We review the credit position and supplier controls so that legitimate credits are protected and can be defended in an audit.

04

Do foreign companies selling services into Bangladesh have to pay VAT?

Tax can apply to services supplied from abroad to customers in Bangladesh. Depending on the type of service and the customer, the Bangladeshi recipient may be required to account for the tax under a reverse charge, or the foreign supplier may need to register, often through a local representative, particularly for digital services sold to consumers. Contracts should state who bears the cost and how deduction at source will be handled. We advise foreign suppliers and local customers on the rules, registration options and the drafting of tax clauses before services begin, so that remittances are not delayed.

05

How is customs value determined for imports into Bangladesh?

Customs value is based primarily on the transaction value, meaning the price actually paid or payable for the goods when sold for export to Bangladesh, adjusted for items such as freight, insurance, certain royalties and assists. Customs may question the declared value where buyer and seller are related, the price appears low against reference data, or the documents are inconsistent. The Customs Act 2023 provides alternative valuation methods when the transaction value cannot be accepted. We help importers prepare valuation support and respond when customs proposes a higher value at clearance. Declared values should match across documents.

06

What happens if customs disputes our tariff classification at clearance?

If customs considers that goods fall under a different heading with a higher rate, it may assess additional duty and tax, delay clearance and propose penalties. The importer can present technical evidence, such as product specifications, test reports and the explanatory notes to the Harmonized System, and may be able to clear goods on payment under protest or against security while the dispute continues. Further remedies include adjudication and appeals. We prepare classification arguments and advise on clearing goods without conceding the point for future shipments. Keep samples and lab reports for each product.

07

Can goods seized by customs at the port be released quickly?

Seized goods can sometimes be released on payment of duties and fines, on provision of security, or after adjudication finds that the seizure was unjustified. The route depends on the reason for seizure, such as misdeclaration, prohibited or restricted goods, missing permits or suspected undervaluation. Time matters, because demurrage and storage charges accumulate quickly at ports and inland depots. We review the seizure documents, communicate with customs officials, prepare written submissions and, where necessary, seek urgent relief from the tribunal or the High Court Division to protect the importer's goods and commercial position. Gather all shipping documents at once.

08

How do we challenge a VAT demand or assessment?

Start by checking the notice, the legal basis and the deadline for response. Many demands arise from reconciliation differences, disallowed input tax credit or deduction at source mismatches, and can be resolved by producing records. If the authority issues a final order, the taxpayer can appeal to the commissioner and then to the appellate tribunal, usually subject to a deposit requirement, with further recourse to the High Court Division on points of law. We review the demand, prepare the response, protect the deadlines and represent the business at each stage. Do not let a response date pass.

How a matter runs

From first call to resolution.

  1. 01

    Diagnose the real issue

    We carefully review the business model, transactions, invoices, returns or import documents and any notices received, and identify the legal questions, risks and deadlines that matter most to the client. Urgent VAT deadlines are flagged immediately.

  2. 02

    Advise and correct promptly

    We explain the correct VAT and customs treatment, recommend changes to contracts, invoicing or declarations, and help the business make corrective filings where these reduce its exposure. We also explain the likely cost and risk of each option.

  3. 03

    Engage the relevant authorities

    We prepare submissions, attend hearings and correspond with officials, coordinating with the client's consultants and C&F agents so that one consistent position is presented to every office. VAT and customs records are kept aligned. Each submission is checked against the underlying records before it is filed.

  4. 04

    Resolve and prevent recurrence

    We pursue appeals or settlement where needed, then update procedures, internal controls and staff training so that the business is better prepared for its next audit, return or shipment. Lessons learned are shared with finance and logistics staff.

“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.

How is the standard VAT rate in Bangladesh set?
The Value Added Tax and Supplementary Duty Act 2012 sets a standard rate, alongside reduced rates, specific amounts, exemptions and supplementary duties for particular goods and services. Rates and schedules are amended through the annual Finance Act and statutory regulatory orders, so businesses should confirm the rate for each supply at the relevant date rather than relying on older guides, price lists or previous invoices from suppliers. VAT on imports follows the same rate schedules. Rates should be rechecked after each annual Finance Act.
Who administers VAT and customs in Bangladesh?
Both are administered by the National Board of Revenue through separate wings, with custom houses at seaports, airports and land stations, commissionerates across the country, and specialist directorates for intelligence and audit. Appeals go to the commissioner and then the Customs, Excise and VAT Appellate Tribunal, with further recourse to the High Court Division on questions of law, procedure and jurisdiction. Each office has distinct powers. Knowing which office has jurisdiction saves considerable time in any dispute.
Are exports zero-rated for VAT in Bangladesh?
Exports of goods and certain services are generally zero-rated, meaning no tax is charged on the export while the exporter may still claim credit or refunds for tax paid on inputs. Exporters must keep evidence of export and of receipt of proceeds through the banking system. Refund claims can be slow, so careful documentation, reconciliation and persistent follow-up with the commissionerate are important for cash flow. Credits not claimed within the allowed period may be lost, so claims should be filed on time. Refund timelines vary considerably in practice.
What is supplementary duty and when does it apply?
Supplementary duty is an additional levy on specified goods and services, such as certain luxury items, tobacco, beverages and some services, under the Value Added Tax and Supplementary Duty Act 2012. It is charged at import or on local supply, alongside value added tax, and the rates are revised through the Finance Act. It affects retail pricing and margins, so it should be modelled carefully before launching new products in Bangladesh. Pricing models should be updated whenever the rates change, so that margins are not eroded.
Can we use alternative dispute resolution for VAT disputes?
Alternative dispute resolution has been available for certain indirect tax and customs disputes, allowing the taxpayer and the authority to reach an agreed settlement with the help of a facilitator. It can be faster and cheaper than litigation, but it is not suitable for every case, and the procedure and eligibility should be checked when a dispute arises. We advise on whether it is the right route for the particular demand. Advice sought before an order is issued gives more options than advice sought afterwards.
Do we need a C&F agent to clear imports at Chittagong or other ports?
In practice, most imports are cleared through a licensed clearing and forwarding agent, who files the bill of entry and deals with customs on the importer's behalf. The importer remains responsible for the accuracy of declarations, so it should control the information given to the agent and review key filings before submission. We advise importers when disputes arise with customs, or with their own agents over errors and charges. Agent errors can be serious. Written instructions to agents help.
Is VAT payable on imported services and software licences?
Often yes. Payments for services, software licences and digital subscriptions from abroad may be taxable in Bangladesh, usually accounted for by the local recipient or, for some consumer services, by a registered foreign supplier. Withholding income tax may also apply to the same payment. Banks often ask for evidence of the tax treatment before remitting payment abroad, so documentation should be prepared before the invoice is due. VAT and withholding often apply together. Contracts should allocate the cost.
How can TRW help with VAT and customs matters?
We advise on registration, compliance, classification, valuation, concessions and contracts, and represent businesses in audits, seizures and appeals, working alongside your consultants and clearing agents. Send a short outline of the issue or the notice received through our contact page or to info@trw.co, and we will confirm scope and fees after a conflict check, usually within a few working days. Full documents are not needed at first contact and can follow once scope is agreed. We can meet at our Mohakhali DOHS office in Dhaka or by video call.

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