Pillar Two Global Minimum Tax & Multijurisdictional Compliance for Bangladesh

by Barrister Tahmidur Rahman | Sep 20, 2026

Trade, Competition & RegulationPillar Two readiness for Bangladesh groups8 min read

Pillar Two Global Minimum Tax & Multijurisdictional Compliance for Bangladesh

We help multinational groups with Bangladesh subsidiaries, branches and economic zone units understand how the Pillar Two global minimum tax affects them, from effective tax rate modelling and incentive planning to data collection, filings, governance and coordination with advisers in every relevant jurisdiction.

Pillar Two Global Minimum Tax & Multijurisdictional Compliance for Bangladesh: global minimum tax with TRW & Co
Matter planTrade, Competition & Regulation
  1. Confirm scope and entities
  2. Model the Bangladesh position
  3. Plan and document
  4. Monitor and defend
Overview

What the global minimum tax means for Bangladesh operations

The OECD's Pillar Two framework introduced a global minimum tax of 15 per cent for large multinational groups, generally those with annual consolidated revenue of at least 750 million euros. Under the Global Anti-Base Erosion (GloBE) Rules, if a group's effective tax rate in a jurisdiction falls below 15 per cent, a top-up tax may be collected, either by that jurisdiction through a domestic top-up tax or by other jurisdictions where the group operates. Our regulatory and corporate teams help groups with Bangladesh operations understand where they stand and what needs to change.

Bangladesh matters to many in-scope groups because of the incentives it offers. Tax holidays, reduced rates for particular sectors, export processing zone and economic zone benefits, and exemptions for specified income can all push the effective tax rate of a Bangladeshi entity below 15 per cent when measured under GloBE rules. Where that happens, the benefit of the incentive may simply move to the parent's jurisdiction as top-up tax. For investors, that changes the value of incentives offered at entry, and it can change how a group thinks about future investment in Bangladesh and the structure it uses.

Bangladesh's domestic rules must be read alongside the GloBE framework. Whether and how Bangladesh introduces domestic minimum tax legislation, such as a qualified domestic top-up tax that would allow it to collect the top-up itself, is a point we monitor through each Finance Act and notification of the National Board of Revenue. Groups should not confuse the global minimum tax with the long-standing Bangladeshi minimum tax on turnover and certain receipts under the Income Tax Act 2023, which is a different concept. Both can apply to the same entity and must be modelled separately and then reconciled carefully.

Pillar Two is as much a data exercise as a tax one. GloBE calculations start from financial accounting figures and require adjustments, covered tax information, deferred tax data and entity classifications that local finance teams may not hold in the required form. Bangladeshi subsidiaries are often asked by headquarters for information they have never had to report, sometimes on short deadlines. We help local management understand the requests, identify legal and tax issues in the data, and ensure that information shared with group and foreign authorities is consistent with Bangladesh filings, transfer pricing documentation and statutory accounts.

Pillar Two also interacts with the Subject to Tax Rule, a treaty-based measure aimed at certain intra-group payments such as interest, royalties and service fees, and with Bangladesh's own withholding regime, including the Finance Act 2026 reduction of withholding on interest paid to non-residents to 10 per cent. Structuring decisions on financing, licensing and services therefore need a combined view. We coordinate with group tax functions and advisers in the UK, US, UAE, Singapore, India and elsewhere, so that the global minimum tax analysis for Bangladesh fits the group's wider compliance position and its dealings with tax authorities.

01 · What we handle

Core workstreams

  • Scope and exposure review
  • Incentive and structure planning
  • Data and reporting readiness
  • Domestic law monitoring
02 · How it runs

Four clear stages

  1. 01Confirm scope and entities
  2. 02Model the Bangladesh position
  3. 03Plan and document
  4. 04Monitor and defend
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 support in-scope groups

Workstream 01Trade, Competition & Regulation

Scope and exposure review

  • Confirm scope and entities
  • Model the Bangladesh position
  • Plan and document
  • Monitor and defend
Workstream 02Trade, Competition & Regulation

Incentive and structure planning

  • Confirm scope and entities
  • Model the Bangladesh position
  • Plan and document
  • Monitor and defend
Workstream 03Trade, Competition & Regulation

Data and reporting readiness

  • Confirm scope and entities
  • Model the Bangladesh position
  • Plan and document
  • Monitor and defend
Workstream 04Trade, Competition & Regulation

Domestic law monitoring

  • Confirm scope and entities
  • Model the Bangladesh position
  • Plan and document
  • Monitor and defend
Workstream 05Trade, Competition & Regulation

Treaty and payment structuring

  • Confirm scope and entities
  • Model the Bangladesh position
  • Plan and document
  • Monitor and defend
Workstream 06Trade, Competition & Regulation

Governance and disputes

  • Confirm scope and entities
  • Model the Bangladesh position
  • Plan and document
  • Monitor and defend
01

Scope and exposure review

We help groups confirm whether they are within scope of the GloBE Rules, identify Bangladeshi constituent entities, permanent establishments and joint ventures, and estimate effective tax rates for Bangladesh using available data. We highlight entities likely to fall below 15 per cent because of tax holidays, zone benefits or exemptions, and explain the likely consequences for the group's global minimum tax position across jurisdictions.

02

Incentive and structure planning

We review existing incentives, tax holiday certificates and zone benefits, and assess how they interact with the GloBE Rules. Where incentives risk being neutralised by top-up tax elsewhere, we consider alternatives such as qualified refundable credits, changes to investment structure, or discussions with authorities, and advise on the legal and practical steps for each option, including approvals that now sit with Invest Bangladesh. Timing matters for each step.

03

Data and reporting readiness

We work with local finance teams and group tax to map the data needed for GloBE calculations, identify gaps between Bangladeshi statutory accounts and group reporting, and resolve legal classification questions about entities, taxes and income. We help prepare internal procedures and documentation so the Bangladesh contribution to group filings is accurate, timely and defensible if questioned later by any tax authority. Reusable data templates are built so that later filings draw on the same reconciled figures.

04

Domestic law monitoring

We track Finance Acts, National Board of Revenue notifications and policy statements for any Bangladeshi measures responding to the global minimum tax, including domestic top-up tax proposals, changes to incentives and treaty developments. We explain what each change means for groups already operating in Bangladesh and for those planning investment, so that decisions are based on the law currently in force and expected changes. Each update sets out what changed, who is affected and what action, if any, is needed.

05

Treaty and payment structuring

We advise on how intra-group interest, royalties, technical fees and service charges paid from Bangladesh are treated under domestic withholding, double tax treaties and the Subject to Tax Rule where relevant. We review loan, licence and service agreements, foreign exchange approvals and transfer pricing support, so that cross-border payments are consistent with the group's Pillar Two analysis and local compliance. Payments shape the global minimum tax result.

06

Governance and disputes

We help boards of Bangladeshi subsidiaries understand their responsibilities when sharing information with the group and foreign authorities, and document decisions on tax positions. Where audits, assessments or disputes arise in Bangladesh, we represent clients before the tax authorities, appellate tribunals and courts, coordinating with foreign advisers where the issue affects global minimum tax filings or positions taken elsewhere. Clear records help in every forum.

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.

Trade, Competition & Regulation 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

Does the global minimum tax apply to our Bangladeshi subsidiary?

The GloBE Rules apply at group level. If your multinational group has consolidated annual revenue of at least 750 million euros in at least two of the four preceding years, its Bangladeshi entities are likely to be constituent entities within scope, and their effective tax rate will be measured for Pillar Two. The subsidiary itself may not owe a new tax in Bangladesh unless Bangladesh enacts domestic rules, but any shortfall below 15 per cent could be collected elsewhere. Smaller groups are outside the rules, though they may still face questions from investors and lenders about the global minimum tax.

02

Has Bangladesh introduced Pillar Two legislation?

We review the position with each Finance Act and National Board of Revenue notification. At present, groups should not assume that Bangladesh has adopted a comprehensive domestic GloBE regime or a qualified domestic top-up tax, and should check the current law before filing or making investment decisions. Even without domestic rules, Bangladeshi entities are affected through the rules of other jurisdictions where the group operates. We confirm the current position for each client rather than rely on general summaries. Each Finance Act should be read for changes to incentives or minimum tax.

03

Will our Bangladesh tax holiday lose its value under the global minimum tax?

Possibly. A tax holiday reduces local tax, which can lower the Bangladeshi effective tax rate under GloBE calculations below 15 per cent. If so, the parent jurisdiction, or another jurisdiction applying the rules, may collect top-up tax on the difference, so the group as a whole may pay similar tax but in a different country. The effect depends on the size of the incentive, substance-based income exclusions for payroll and tangible assets, and the group's overall position. We help model the outcome and consider whether alternative incentive structures or investment approaches would preserve more value.

04

Is the Bangladesh minimum tax the same as the global minimum tax?

No. Bangladesh has long applied a minimum tax under its income tax law, generally calculated on turnover or certain receipts, which can apply even when a company makes losses. That domestic regime is separate from the GloBE Rules, which measure the effective tax rate on accounting profits in each jurisdiction against a 15 per cent benchmark. A Bangladeshi entity may pay domestic minimum tax and still have a GloBE effective tax rate below 15 per cent, or the reverse, so both must be documented under their own rules. We map how domestic minimum tax feeds into the GloBE calculation.

05

What information will our group headquarters ask our Bangladeshi subsidiary to provide?

Typically, financial accounting data used for consolidation, adjustments required by the GloBE Rules, current and deferred tax information, details of taxes paid including withholding, entity ownership and classification, payroll and tangible asset figures for substance-based exclusions, and information about incentives and their terms. Local teams may need to extract data from different systems or reconcile statutory and group accounts. We help Bangladeshi subsidiaries understand requests, flag legal issues such as classification of particular taxes or entities, and ensure the information provided is consistent with local filings and documentation. Early engagement with headquarters helps the global minimum tax return.

06

Do economic zone and EPZ benefits matter for the global minimum tax?

Yes. Units in export processing zones under BEPZA, economic zones now administered by Invest Bangladesh following the August 2026 merger, and hi-tech parks often enjoy tax holidays and exemptions that reduce local tax. Under the GloBE Rules, those benefits can lower the Bangladeshi effective tax rate. The value of the zone package to the group depends on whether top-up tax arises elsewhere. When negotiating new investments or expansions, groups should model the global minimum tax effect and consider whether non-tax benefits, such as infrastructure, customs facilitation or faster approvals, offer value that survives Pillar Two.

07

How does the Subject to Tax Rule affect payments from Bangladesh?

The Subject to Tax Rule is a treaty-based measure designed to allow source countries to tax certain intra-group payments, including interest, royalties and some service fees, where the payment is taxed below a minimum nominal rate in the recipient's jurisdiction. It operates through bilateral treaties or a multilateral instrument, so it applies only where the relevant treaty has been amended and the change is in force. Bangladesh already imposes withholding on many outbound payments. We review the treaty position and domestic withholding together, so that groups understand their actual tax cost on payments from Bangladesh.

08

Can Pillar Two lead to tax disputes with the National Board of Revenue or foreign authorities?

Yes. Disputes may arise over the classification of taxes, entities or income, the treatment of incentives, transfer pricing adjustments that affect profits in several jurisdictions, and inconsistencies between information filed in different countries. Bangladeshi tax authorities may also scrutinise intra-group payments more closely as information exchange increases. Good documentation, consistent positions and early engagement reduce risk. Where disputes arise in Bangladesh, we represent clients in assessments, appeals and tribunal proceedings, and coordinate with foreign advisers so that the global minimum tax consequences are managed consistently across the group. Consistency is the key safeguard.

How a matter runs

From first call to resolution.

  1. 01

    Confirm scope and entities

    We confirm whether the group is in scope, identify Bangladeshi constituent entities and permanent establishments, and collect the incentive certificates, accounts and tax filings needed for an initial review of exposure. We also note filing deadlines in each relevant country.

  2. 02

    Model the Bangladesh position

    With group tax and accountants, we estimate GloBE effective tax rates for Bangladesh, identify likely top-up tax and explain the legal drivers, including incentives, withholding and domestic minimum tax. Assumptions and data gaps are recorded clearly. Results are explained in plain terms.

  3. 03

    Plan and document

    We recommend structural, contractual and governance steps, help prepare data procedures and documentation, and align Bangladesh filings, transfer pricing support and group global minimum tax reporting. Each step is assigned an owner and a date.

  4. 04

    Monitor and defend

    We track Bangladeshi and treaty developments, update analysis when laws change, and represent the client in audits, assessments and appeals arising from the Bangladesh position. Lessons from each global minimum tax cycle feed into the next year's process. Clients are alerted when a change affects an open filing or a planned investment.

“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 the global minimum tax rate under Pillar Two?
The GloBE Rules set a minimum effective tax rate of 15 per cent, measured jurisdiction by jurisdiction for in-scope multinational groups. The effective rate is calculated using adjusted accounting profits and covered taxes, not headline statutory rates. A jurisdiction with a high statutory rate can still produce a low GloBE rate where incentives, exemptions or timing differences apply, so modelling is essential for every country in the group. The global minimum tax therefore requires country-level modelling, not a single group-wide calculation.
Does the global minimum tax affect Bangladeshi-headquartered groups?
Only a small number of Bangladeshi-headquartered groups are likely to meet the 750 million euro revenue threshold. Those that do and have foreign subsidiaries may face top-up tax in other jurisdictions where they operate, depending on local rules there. Larger Bangladeshi groups below the threshold should still monitor developments, as joint venture partners, foreign lenders and acquirers increasingly ask about exposure. Early planning keeps options open if the group grows. Investors increasingly ask about this.
What is a qualified domestic minimum top-up tax?
It is a domestic tax that a jurisdiction can introduce to collect top-up tax on low-taxed profits of entities located there, before other jurisdictions apply their rules. If it meets the OECD standards, other jurisdictions generally credit it. Many countries have introduced one so that they, rather than the parent's country, collect the additional tax. Any Bangladeshi move in this direction would be announced through legislation. Groups should model the global minimum tax with and without such a tax in Bangladesh, so that investment cases remain robust either way.
Are withholding taxes paid in Bangladesh treated as covered taxes?
Taxes withheld on income of a Bangladeshi entity are generally relevant in computing its covered taxes, and withholding on distributions or other payments may be allocated under specific GloBE rules. The precise treatment depends on the nature of the tax and the payment. We help groups classify Bangladeshi taxes correctly, including minimum tax, withholding and surcharges, because the classification can materially change the effective tax rate. Errors in classification can distort the global minimum tax outcome for several years.
Should we change our Bangladesh investment plans because of Pillar Two?
Not necessarily, but plans should be tested. If the business case relies heavily on tax holidays, the global minimum tax may reduce their value for an in-scope group. Other factors, such as market access, costs, workforce and non-tax incentives, remain important. We help investors model the impact and negotiate with authorities or adjust structures where it makes sense, based on current law. Decisions should be documented and revisited as the law develops. Non-tax factors may outweigh tax.
What are the substance-based income exclusions, and do they help Bangladeshi manufacturers?
The GloBE Rules exclude a return on payroll costs and tangible assets in each jurisdiction from the profit subject to top-up tax, reducing exposure for groups with real operations. Labour-intensive manufacturing in Bangladesh may therefore benefit from a meaningful exclusion. Accurate data on eligible payroll and tangible assets is needed to claim it, and the transitional percentages decline over time. Manufacturers should collect this data early, since the global minimum tax exclusion depends on reliable payroll and asset records.
Do Bangladeshi directors face personal risk under Pillar Two?
The GloBE Rules themselves impose obligations on entities rather than directors. However, directors of Bangladeshi subsidiaries remain responsible for accurate local filings, records and statutory accounts, and inconsistent information can create local tax and regulatory risk. Boards should understand how group requests affect the subsidiary and record their decisions on significant tax positions. Training for local finance and tax teams on the global minimum tax helps reduce these risks and improves the quality of data supplied to headquarters.
How do we start a global minimum tax review with TRW?
Send us a summary of your group, its Bangladeshi entities, incentives and any information requests already received from headquarters. We will propose a focused review and identify the accountants and foreign advisers to involve. Contact us through our contact page, by telephone on +880 1708 000660 or by email at info@trw.co. We can usually schedule an initial call within a few working days, and we tailor the review to the group's reporting calendar and deadlines. We coordinate closely with your accountants.

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