They can be relevant where a Bangladesh-linked entity enters into a cross-border transaction with an associated enterprise. The analysis commonly begins with the relationship between the entities, the nature of each transaction and the relevant income year. Purchases and sales are only part of the picture: services, use of intangibles and group funding can also require attention. The position depends on the facts, current law and the documents in place.

A useful starting point is a complete transaction inventory, current intercompany agreements, a clear explanation of the commercial arrangement and the information needed for the statement of international transactions. It also helps to identify who holds the relevant records across legal, finance and operational teams. The level and form of documentation depend on the transaction and current requirements.

A group policy can be an important starting document, but it should be tested against the Bangladesh entity’s actual transactions, contractual terms, functions, assets, risks and available evidence. A position is easier to explain when the documentation and operational reality tell the same story. Specific advice may be appropriate before relying on a policy for a particular transaction or filing.