No. A double tax treaty may entitle the recipient to a lower rate, but in Bangladesh the payer generally withholds at the domestic rate unless there is a proper basis to apply the treaty rate, which usually means a certificate from the National Board of Revenue or equivalent evidence accepted under current practice. The recipient will need to show residence in the treaty country and, in most cases, beneficial ownership. Without that, the payer bears the risk of under-deduction. We advise both payers and recipients on assembling the evidence and on applying for the certificate before payment.

Bangladesh has double tax treaty arrangements with a substantial number of countries, including many of its main sources of investment and trade such as the UK, US, India, China, Singapore and the UAE, as well as a range of European and Asian countries. New treaties and protocols are signed from time to time, and a signed treaty may not yet be in force. Because rates, definitions and conditions vary significantly between treaties, it is essential to work from the current official text for the specific country rather than a general table or a summary prepared years ago.

Under Bangladesh domestic law, interest paid to non-residents is subject to withholding, now 10% under the Finance Act 2026, reduced from 20%. Many treaties cap the source country's tax on interest at a rate that may be the same as, or lower than, the new domestic rate, and some exempt interest paid to government lenders or specified institutions. The lender must still show residence and beneficial ownership. Because the domestic rate has fallen, lenders should check whether a treaty claim still adds value before investing time in the certificate process for each facility.

Yes. Under a double tax treaty, a foreign company becomes taxable on business profits in Bangladesh if it has a permanent establishment there. That can arise from a fixed place of business, a construction or installation project lasting longer than a stated period, services provided by staff present in Bangladesh for a certain time, or a dependent agent who habitually concludes contracts. The thresholds vary between each double tax treaty. Domestic law also contains its own rules on income deemed to arise in Bangladesh. We review operating models and contracts to identify and manage this risk.

Royalties, licence fees and fees for technical services paid to non-residents are subject to withholding in Bangladesh, and remittance usually also requires compliance with foreign exchange rules. Treaties differ on whether technical fees are treated as a separate category, as business profits taxable only if there is a permanent establishment, or within the royalty article. The characterisation of each payment under the contract and the relevant double tax treaty therefore matters. We review licence and service agreements so that the description of the services matches the treaty article relied on and the documents the NBR will expect.

Typically, a valid tax residence certificate issued by the recipient's home tax authority for the relevant period, the underlying agreement, invoices, evidence of the payment and its purpose, and information showing that the recipient is the beneficial owner and has real substance. Corporate documents and financial statements may be requested. Certified translations and notarisation may be needed for foreign documents. Requirements and practice change from time to time, so the current list should be confirmed before applying. We prepare complete applications, which reduces the risk of rejection or repeated requests for further information.

They can, and increasingly are. Many treaties include beneficial ownership requirements, and modern treaties and protocols may contain anti-abuse provisions directed at arrangements whose main purpose is to obtain treaty benefits. A holding or finance company in a treaty country that passes income straight on to its parent elsewhere, with no staff, decision-making or risk, is vulnerable to challenge. Domestic anti-avoidance rules may also apply in some cases. We assess existing and proposed structures realistically, advise on substance where a structure is commercially justified, and explain where a double tax treaty claim is unlikely to succeed.

The recipient may often be able to claim a refund of the excess from the NBR, supported by evidence of treaty entitlement, although refunds can take time. Alternatively, it may claim a foreign tax credit in its home country for the Bangladesh tax deducted, but many countries only give credit up to the treaty rate, so excess Bangladesh tax may be a real cost. Where the dispute cannot be resolved domestically, the treaty's mutual agreement procedure may be available within its time limits. We advise on the best route and prepare the full claim with supporting evidence.