VAT Refund in Bangladesh: Eligibility, Exporter Claims, e-VAT and Appeals in 2026

by Barrister Tahmidur Rahman | Oct 20, 2026 | Insights, Tax & Regulatory | 0 comments

TRW Insight / Bangladesh

Excess input tax is money the business has already paid. Recovering it depends on the six-period rule, the exporter gateway in section 69, a complete e-VAT return history and a file that survives scrutiny, and on knowing where to go when the claim is refused.

Updated 20 October 2026Legal insightBangladesh24 min read

VAT refund Bangladesh law in 2026: where a refund comes from

VAT refund Bangladesh claims are where a well-run VAT position turns into cash, or fails to. Exporters, deemed exporters, capital-intensive manufacturers and businesses that pay heavy advance tax at import routinely build up more input tax than output tax. The Value Added Tax and Supplementary Duty Act 2012 gives them a statutory route to recover that money, but it is a route with gates: a six-period carry-forward, a Tk 50,000 floor, a three-month payment period, a requirement that every return be on the system, and a Commissioner who must be satisfied before paying.

This guide is about getting the money back and defending the claim when it is challenged. It explains the refund provisions in Chapter X of the Act (sections 68 to 72), the exporter route under section 69, the supporting rules and Mushak forms, the NBR's online refund module and the automated bank-transfer system launched in January 2026, duty drawback under the Customs Act 2023, and the appeal and ADR routes when a refund is refused or clawed back. It builds on, and does not repeat, our guides to VAT in Bangladesh, VAT return filing and VAT compliance.

VAT refund Bangladesh — finance team reviewing input tax records before a refund claim
Every refund starts with input tax the business can prove

Summary: A registered person whose input tax and decreasing adjustments exceed output tax carries the excess forward for six tax periods and can then claim a refund, payable within three months of application if the balance exceeds Tk 50,000. Exporters and other businesses that structurally generate excess credit can claim straight away under section 69. Claims are made through the Mushak-9.1 return on e-VAT, and refused or reversed refunds are challenged before the Commissioner (Appeal), the Appellate Tribunal or through ADR.

Key point: No refund is paid under sections 68 or 69 until the applicant has filed all VAT returns up to the current tax period, and any refund is first set off against outstanding VAT, interest and penalties. Since January 2026 approved refunds are paid by the NBR directly into the taxpayer's bank account through BEFTN, and the NBR has said it will not make paper-based refunds.

At a glance

01

Six periods

Excess credit is carried forward and set off for six tax periods before a refund can be claimed under section 68.

02

Tk 50,000 floor

A residual balance at or below Tk 50,000 keeps being carried forward instead of being refunded.

03

Three months

The Commissioner must pay a qualifying refund within three months of receiving the application.

04

Exporter route

Section 69 lets businesses with 50% or more zero-rated turnover claim without waiting out the carry-forward.

05

Bank transfer

The e-VAT refund module pays approved claims through iBAS++ and BEFTN, with no cheque collection.

Table of Contents

Where a VAT refund Bangladesh claim comes from: Chapter X of the Act

Bangladesh runs a credit-invoice VAT: output tax less input tax gives the amount payable. When the difference is negative, the Act calls it a negative net amount, and Chapter X decides what happens to it. The rules are in sections 68 to 72 of the Value Added Tax and Supplementary Duty Act 2012, as published in the authentic English text of November 2025.[1] Section 67, which is sometimes cited in this context, in fact deals with orders to file complete, additional or alternative returns; the refund provisions begin at section 68.

The five statutory routes

Chapter X contains five distinct entitlements. Section 68 governs carry-forward and refund of a negative net amount. Section 69 allows refund without carry-forward for exporters and businesses that structurally generate excess credit. Section 70 sets the conditions that apply to both: all returns filed, set-off against arrears and a discretion for small balances. Section 71 covers refunds of tax paid by diplomatic missions and international organisations. Section 72 deals with tax paid in excess of the amount shown in the return and tax paid by mistake by an unregistered person.[1] Outside Chapter X, section 31 allows an unregistered person who has paid advance tax at import to apply for its refund, and rule 56 of the VAT and Supplementary Duty Rules 2016 creates a VAT refund scheme for foreign tourists.[1] [2]

Who can claim

The carry-forward and refund mechanism under sections 68 and 69 is available to a registered person who claims input tax credit and files a Mushak-9.1 return. A turnover-tax enlisted business and a trader filing Mushak-9.1.1, which does not permit credit claims, has no negative net amount to recover in the same way.[3] The first task in any VAT refund Bangladesh file is therefore to identify which entitlement the money falls under, because each has its own form, time limit and decision-maker.

VAT refund routes in Bangladesh: basis, claimant and timing
RouteLegal basisWho claimsFormTiming
Carry-forward then refundAct s 68; Rule 52Registered person with excess creditMushak-9.1After six periods; paid within 3 months if above Tk 50,000
Refund without carry-forwardAct s 69; Rule 52Exporters and structural excess-credit businessesMushak-9.1Within 3 months of application if above Tk 50,000
Excess paymentAct s 72(1); Rule 52(6)-(7)Person who overpaid against its returnReturn or VAT-9.1Adjust within six periods, then apply
Advance tax at importAct s 31; Rule 19(3)Ultimate consumer or unregistered importerVAT-4.1Apply within 120 days; paid within 15 days
Diplomatic and international bodiesAct s 71; Rule 55Missions and international organisationsApplicationApply within 6 months; paid in 2 or 3 months
Foreign touristsRule 56Foreign touristVAT-10.2 certificateAt the airport customs desk
Customs drawbackCustoms Act 2023 ss 36-40Exporter or re-exporterDEDO claimWithin 6 months of export

Carry forward first: section 68 and the six-period rule

The default position is that excess credit is not refunded immediately. Section 68(1), substituted by the Finance Act 2020, provides that where input tax and receivable decreasing adjustments exceed output tax, supplementary duty and increasing adjustments for a tax period, the excess is carried forward and may be set off in the next six tax periods; only what remains after that is refunded under the section.[1]

How the set-off works

Section 68(2) sets the order of operations. In each later period, the tax payable is first calculated on all output tax and adjustments other than the carried-forward amount. If that figure is positive, the brought-forward excess is applied as a decreasing adjustment to reduce the payable amount to nil. Any part that cannot be used is carried forward again until it is fully absorbed, or until that period's excess has been carried forward for six tax periods.[1] Each period's excess runs on its own six-period clock, so track the age of every balance, not just the total.

The Tk 50,000 floor

Under section 68(3), once a balance has been carried forward for six tax periods, two outcomes are possible. If the unadjusted amount does not exceed Tk 50,000, it continues to be carried forward until it is reduced to nil. In any other case, it must be refunded on the prescribed terms within three months of receipt of an application.[1]

Making the application

Rule 52 of the 2016 Rules provides that the registered person applies to the Commissioner in form VAT-9.1, which is the return itself, and that if the application is proper the Commissioner deposits the refundable amount in the applicant's bank account, subject to section 70, or issues a crossed cheque. Under rule 52(5) the deposit must be made within three months of receipt of the application.[2] Because the application is made through the return, the three-month clock starts only when the refund is requested in it.

Immediate refunds under section 69: exporters and structural excess credit

Section 69 is the provision that matters most to exporters. Notwithstanding section 68, a registered person whose net amount is negative is entitled to a refund without first carrying it forward, if the Commissioner or Director General is satisfied that one of four conditions is met.[1]

The four gateways

  • Zero-rated turnover: 50% or more of the person's turnover is or will be derived from zero-rated supplies under Chapter III of the Act.
  • Zero-rated inputs: 50% or more of the person's expenditure on inputs is on imports or acquisitions used in manufacturing zero-rated supplies.
  • Structural excess credit: the nature of the person's economic activity regularly results in excess input tax credit or decreasing adjustment. This clause was substituted by the Finance Act 2023, and the words "or decreasing adjustment" were added by the Finance Ordinance 2025.
  • Supplementary duty on export inputs: supplementary duty paid at import on inputs for exported goods is decreasing-adjustable, and the person does not supply supplementary-duty goods locally.

The Finance Ordinance 2025 also extended the decision-making power from the Commissioner alone to the "Commissioner or Director General".[1] The structural-excess gateway is often overlooked: a non-exporter whose inputs regularly bear more tax than its outputs can use it, if it can show the pattern is regular. For a VAT refund Bangladesh exporters claim, the 50% tests are the usual route.

Thresholds and timing

Under section 69(2), where an application is made, an amount not exceeding Tk 50,000 is carried forward as a decreasing adjustment in the next tax period; in other cases the Commissioner must refund the money within three months from the date of the application.[1] Section 70 applies to section 69 refunds in the same way as to section 68 refunds, so an exporter with an unfiled return or an outstanding demand will find its refund delayed or reduced.

Deemed exports and backward linkage suppliers

Local suppliers to export factories often sit inside the refund chain. Rule 18B requires a bona fide exporter buying under an internal back-to-back letter of credit to hold a bonded warehouse or special bonded warehouse licence, and requires the supply details to appear in the Utilisation Permission or Utilisation Declaration, a copy of which is attached to form VAT-7.1 where supplementary duty is adjusted under rule 45. If the exporter fails to export the goods, it must refund the rebate or credit received within two years of receipt of the goods at the bonded warehouse or within the export letter of credit deadline, whichever is earlier.[2]

Rule 18C treats supplies by backward linkage industries to 100% export-oriented bonded factories as deemed exports, subject to conditions. To claim credit and decreasing adjustments, the supplier must hold the UP or UD, a bank-certified copy of the letter of credit, a certificate of receipt of foreign exchange, its BIN, Mushak-6.3 invoices, the goods declarations for imported inputs, and an undertaking on Tk 300 non-judicial stamp paper, and must report the benefit in each Mushak-9.1 return and in half-yearly statements filed in January and July.[2]

Supplementary duty on exports

Rule 45, substituted from 1 July 2025, requires a registered person to take the decreasing adjustment for supplementary duty on export inputs within six months of export or loading, extendable by a further six months with the divisional officer's approval. The supporting file must include the release order or goods declaration with proof of payment, the customs-certified invoice and packing list, the bill of lading, airway bill or truck receipt, the export general manifest where applicable and the certificate of proceeds realisation.[2] An exporter who misses that window cannot repair it by amending the return, because rule 49(1A) bars amendment for a failure to take an adjustment or rebate within the prescribed period.[2]

VAT refund Bangladesh — container port where exporters claim refunds under section 69
Exporters with zero-rated turnover can claim without waiting out the carry-forward

Section 70 conditions: returns, set-off and the e-VAT history

Section 70 applies three conditions to every refund under sections 68 and 69. First, no refund is made unless the applicant has filed all VAT returns up to the current tax period. Second, a refund that becomes payable is applied first to reduce any outstanding liability for tax, interest, penalty or fines under the Act. Third, if what remains does not exceed Tk 50,000, the Commissioner may decline to refund it and instead permit the registered person to treat it as a decreasing adjustment in a tax period set by the Board; rule 54 links that adjustment back to section 68(3).[1] [2]

Every return, on the system

The first condition has acquired practical force with the move to online administration. Under a circular of 5 January 2026, businesses that had filed paper returns were required to enter them in the e-VAT "Hard Copy Return Entry" sub-module, with the deadline extended to 30 June 2026. The NBR warned that closing balances as of May 2026 would be frozen for businesses that missed the deadline and that all VAT returns must be in the online system for refund applications to be processed.[11] Completing that exercise is the first step of any refund claim. The mechanics are covered in our VAT return filing guide.

Monthly returns are back

The return cycle also matters, because the refund is claimed through the return. The Finance Act 2026 made quarterly returns the default from July 2026, but the Value Added Tax and Supplementary Duty (Amendment) Ordinance 2026, gazetted on 14 October 2026, restored monthly returns due within 15 days after each tax period, with 20 days for government bodies, banks, insurers and nil-return filers. An NBR VAT Policy member said the quarterly system had complicated rebates, adjustments and refunds. The NBR extended the deadline for online returns for July to September 2026 to 25 October 2026 without interest or penalty.[10] For a business in a refund position, each month's excess now starts its own six-period clock.

Set-off against arrears

The set-off rule means a refund can disappear into an unrelated demand. Unless a disputed demand has been stayed or set aside, expect the Commissioner to apply the refund to it, and document any stay and pre-deposit in the refund file.

Other refund routes: excess payments, advance tax, diplomats and tourists

Not every VAT refund Bangladesh taxpayers pursue arises from excess credit. Several routes recover money that should never have been paid.

Tax paid in excess of the return

Under section 72(1), tax paid in excess of the amount shown as payable in the return may be claimed as a refund by application or shown as a decreasing adjustment within six tax periods in the next return.[1] Rule 52(6) and (7) set the order: take the decreasing adjustment within the next six tax periods and, if that is not possible, apply to the Commissioner in form VAT-9.1 for a refund.[2] Section 72(2) allows the Commissionerate into whose economic code the money was deposited to refund tax paid by mistake by an unregistered person.[1]

Advance tax at import

A registered person who pays advance tax at import takes it as a decreasing adjustment in its return under rule 19(1) and (2). A person who is the ultimate consumer of imported goods and will not transfer them may apply for a refund of the advance tax in form VAT-4.1, online or on paper, within 120 days of payment; the Commissioner must approve and pay within 15 days of receipt of a proper application.[2] Section 31(4) separately allows an unregistered person who has paid advance tax to apply to the Commissioner for its refund.[1] In practice, advance tax that exceeds a business's actual VAT liability is one of the commonest reasons a refund arises at all.[7]

Diplomatic missions and international organisations

Section 71 provides that VAT exemptions for supplies to diplomatic and consular missions and international organisations, and supplies exempt under international conventions, take effect by refund rather than by exempting or zero-rating the supply. Under rule 55 the responsible officer of the mission or organisation applies with documentary evidence of payment within six months of payment, and the refund is paid within two months of an online application or three months of any other application. Any difference between the amount claimed and the amount approved must be explained by notice, with a hearing if requested.[1] [2]

Foreign tourists

Rule 56 entitles a foreign tourist to a refund of VAT on taxable goods bought from shops displaying the "VAT Refund for Tourists" sign. The seller issues a VAT Refund Certificate in form VAT-10.2, and the refund is paid at the customs "VAT Refund" desk at the international airport on production of the certificate and the goods, less a service charge. Export-prohibited goods are among the exclusions.[2]

VAT collected without authority

Where VAT has been collected with no legal basis, the High Court Division will intervene. In Pragati Life Insurance Ltd v Bangladesh (Writ Petition No. 2242 of 2023, judgment of 6 June 2024), the Court held that a Sub-Registrar's 2% VAT levy of Tk 1.30 crore on registration of a sale deed between parties who were not real estate developers was made without lawful authority, condoned the time limit under rule 52, and directed the NBR to refund or adjust the amount if the petitioner applied in form Mushak-9.1 within six months of receiving the judgment.[12] A writ can therefore unlock a refund the statutory scheme would time-bar, but only where the collection was unlawful from the outset. Our guide to writ petitions in Bangladesh explains the procedure.

The NBR e-VAT refund system: from online module to automated payment

For years the practical problem in VAT refund Bangladesh practice was not entitlement but payment: applications sat in commissionerates, cheques were collected in person and the statutory three months was routinely exceeded. The NBR's response came in two stages.

November 2025: the online refund module

On 10 November 2025 the NBR announced an online VAT refund module that links the Integrated VAT Administration System (iVAS) with the Finance Division's iBAS++ system and pays approved refunds through the Bangladesh Electronic Fund Transfer Network (BEFTN). The commissionerate verifies the claim made in the return, and the approved amount is transferred automatically.[4] [5] The NBR also required taxpayers to file new applications on Mushak-9.1 through iVAS, including for unresolved claims previously filed online or on paper, and said officers in all commissionerates had been trained.[5]

January 2026: automated bank transfer goes live

On 7 January 2026 the NBR Chairman, Md Abdur Rahman Khan, inaugurated the automated e-VAT refund system at Revenue Bhaban in Agargaon. Taxpayers register their bank account once and click a "refund request" button in the monthly online return; once a commissionerate approves the claim, payment is initiated automatically from Bangladesh Bank through BEFTN. At launch Tk 45.35 lakh was transferred to three taxpayers from three Dhaka commissionerates, and the NBR reported 115 refund applications totalling Tk 124.49 crore in the new system. The Chairman said the NBR would not give paper-based refunds.[6]

What automation does not change

The system automates payment, not the decision. A commissionerate still examines and approves each claim, and the Act's requirement that the Commissioner or Director General be satisfied under section 69 remains. An NBR official said refunds often took six to 12 months under the old system, and outstanding refund liabilities across taxes and VAT stood at about Tk 4,000 crore. The BKMEA president said exporters had avoided applying because of paperwork, multiple approvals and informal payments.[7] Clean documentation, not the portal, still drives speed.

2026: the end of manual refund channels

In July 2026 the NBR's VAT Implementation Wing proposed cancelling the general order that allowed VAT refunds on jute and leather raw materials to be processed manually through the Duty Exemption and Drawback Office (DEDO), a special arrangement introduced in March 2023, so that e-VAT would become the only refund channel for those exporters. The NBR Member for VAT Implementation and IT said all VAT refunds must be processed through VAT returns in the e-VAT system and paid through iBAS++. DEDO would continue to handle customs duty and regulatory duty refunds manually until they are automated.[8] Jute exporters reported long-pending claims stuck because they had not filed nil returns, which is a direct consequence of the section 70 condition.[8]

Step 01

Identify the route

Decide whether the money falls under section 68, 69, 71 or 72, section 31 or rule 56, because each has its own form, clock and decision-maker.

Step 02

Close the return history

Confirm every return up to the current period is filed online, including paper returns entered through the Hard Copy Return Entry sub-module.

Step 03

Clear or contest arrears

List outstanding demands, interest and penalties, since section 70 sets them off first, and secure stays where an appeal is pending.

Step 04

Build the evidence file

Reconcile Mushak-6.3 invoices, goods declarations, purchase and sales books and VAT-6.10 data, plus export documents and UP or UD for deemed exports.

Step 05

Register the bank account

Record the designated bank account in e-VAT so an approved refund can be paid through iBAS++ and BEFTN.

Step 06

Request the refund in Mushak-9.1

Use the refund request in the return for the period in which the six-period window closes or the section 69 condition is met.

Step 07

Track the three months

Diarise the statutory three-month payment period and respond quickly to commissionerate queries.

Step 08

Escalate or appeal

If the claim is refused or reduced, appeal within 90 days, consider ADR under section 125, or a writ where collection was unlawful.

Mushak forms and the refund file

A refund is only as strong as the documents behind the input tax it recovers. The forms that matter most are these.

  • Mushak-9.1: the VAT return, which under rule 52 is also the refund application and, since 2026, carries the online refund request.[2] [6]
  • Mushak-6.3 tax invoices and goods declarations: the primary evidence of every input tax amount claimed.
  • Purchase and sales books (Mushak-6.1, 6.2 and 6.2.1) and the VAT-6.10 large-invoice statement: the records against which the NBR matches supplier output tax to buyer input credit.
  • Mushak-4.3: the input-output coefficient declaration, which the Finance Act 2026 clarified is filed after manufacture but before supply.[3]
  • VAT-7.1: used with the UP or UD for decreasing adjustment of supplementary duty on deemed exports.[2]

For exporters, the export documents matter as much as the input side. Records maintained in ERP systems are now accepted as valid documents and may be submitted online under the Finance Act 2026.[3] The bookkeeping standards that make these documents audit-ready are set out in our VAT compliance guide.

Timelines: the clocks that run on a refund

VAT refund Bangladesh claims run on several clocks at once, some binding the taxpayer and others the NBR.

  • Six tax periods: the carry-forward period under section 68 and the window for a decreasing adjustment of excess payments under section 72 and rule 52(6).[1] [2]
  • Three months: the period within which the Commissioner must refund under sections 68(3) and 69(2) and rule 52(5).[1]
  • Six months, plus six: the window for adjusting supplementary duty on exports under rule 45.[2]
  • Five years, or three for 100% export-oriented industry: the limit on tax determinations under section 73(3), lifted where a refund was claimed fraudulently.[1]
  • Six months from export: the deadline for a customs drawback claim under section 38 of the Customs Act 2023.[9]

Chapter X does not provide for interest to be paid to the taxpayer when the NBR pays late. Section 127(3) refunds interest a taxpayer paid on an amount later found not payable, but that is different from compensating for delay.[1] A taxpayer facing a refund that is well past three months has to rely on escalation within the NBR, a writ petition or, where the claim has been refused, an appeal.

Duty drawback and customs refunds for exporters

Drawback is the customs counterpart of a VAT refund and is governed by Chapter VII of the Customs Act 2023, not by the VAT Act. Under section 36(1), duties paid on identifiable imported goods that are re-exported, loaded as stores for a conveyance bound abroad, destroyed under supervision or handed over to the Government may be repaid as drawback up to seven-eighths of the duty, provided the goods were not used in Bangladesh and are identified as the same goods by an officer of at least Assistant Commissioner rank. The time cannot be extended beyond three years after importation.[9] Under section 36(2), the Board may by notification allow drawback on goods used to manufacture exported products, to the extent and on the conditions set by rules.[9]

When drawback is refused

Section 38 allows no drawback on goods required to be, but not, included in the export cargo declaration; where the claim on a single shipment is below Tk 2,000; or unless the claim is made and established at the time of export or within six months of export. Under section 39, drawback is paid without undue delay but not until the vessel has put out to sea or the conveyance has left Bangladesh, and section 40 requires a declaration that the goods have not been and will not be re-landed.[9] Customs refunds outside drawback are subject to a separate three-year limit under section 34.[9]

DEDO and the interaction with VAT

The Customs Act lists a Director General (Customs Exemption and Drawback) among the customs officers, and DEDO administers drawback claims.[9] As reported in July 2026, DEDO continues to process customs duty and regulatory duty refunds by manual verification, while VAT refunds are being moved entirely to e-VAT.[8] A VAT credit recovered through section 69 cannot also be recovered as drawback, and section 73(1)(d) of the VAT Act lets the VAT authority raise a tax determination where a person has been paid a refund or given a drawback to which it was not entitled.[1] The wider customs regime is covered in our guides to customs law in Bangladesh and export law in Bangladesh.

VAT refund Bangladesh — shipping documents used for duty drawback and export refund claims
Bills of lading and proceeds certificates carry the export side of the file

When a refund is refused or reversed: VAT disputes and appeals

A VAT refund Bangladesh dispute takes one of two forms: the commissionerate refuses or reduces the claim, or it pays and later seeks the money back. The forum and time limits depend on who made the decision.

Claw-back through a tax determination

Section 73(1)(d) allows a primary show-cause notice where a person has been paid a refund or given a drawback to which it was not entitled. The taxpayer may object in writing within the period in the notice and must be heard; the officer then has 120 days from the objection, or from the notice if no objection is filed, to make a final determination stating the reasons, the amount, the payment date and the appeal route. Penalty under section 85 may be included in the same notice.[1] Section 73(4)(b) allows interest to be computed from the date the refund was paid, and section 127 charges simple interest at 1% per month, capped at 24 months.[1] A reversed refund can cost far more than the refund itself. Audit-triggered claims follow the same route; the audit process is explained in our tax audit guide.

Appeal to the Commissioner (Appeal)

Under section 121, a decision or order of an Additional Commissioner or a lower-ranking VAT officer can be appealed to the Commissioner (Appeal) within 90 days from the date of issue, extendable by a further 60 days for obvious reasons. The appeal must be disposed of within one year, failing which it is deemed allowed. The Commissioner (Appeal) may uphold, change or set aside the order but may not remand the case de novo.[1] Rule 98 requires a hearing date to be fixed within seven days of receipt of the appeal.[2] The Finance Act 2026 cut the pre-deposit from 10% to 1% of the tax demanded, excluding penalty.[3] A refund refusal involves no demand, so the deposit question arises mainly in claw-back cases.

Appeal to the Appellate Tribunal

Under section 122, a decision of a Commissioner, the Commissioner (Appeal), a Director General or an officer of the same rank goes to the Customs, Excise and VAT Appellate Tribunal within 90 days of service, with a further 60 days if the President is satisfied there was reasonable cause. The Tribunal can stay collection, but a stay lapses after six months unless the case is decided, and an appeal not decided within two years is deemed allowed.[1] The pre-deposit fell from 10% to 1% under the Finance Act 2026.[3] Because section 123 makes the Commissioner's affidavit conclusive unless rebutted, the taxpayer must come with documentary evidence, not argument alone.[1]

Registration of the appeal can itself become contentious. In Md Syed Hossain v Customs, Excise and VAT Appellate Tribunal (Writ Petition No. 12872 of 2022, judgment of 30 January 2024), the High Court Division directed the Tribunal to register an appeal against a VAT demand where the pre-deposit had been paid, leaving limitation for the Tribunal to decide.[13]

The High Court Division

Under section 124, a person or a VAT officer of at least Commissioner rank aggrieved by an order of the Board or the Appellate Tribunal may appeal to the High Court Division on questions of law. The Code of Civil Procedure applies as far as possible, and section 5 of the Limitation Act 1908 applies to the filing.[1] The pre-deposit was cut from 10% to 2% by the Finance Act 2026.[3] The scale of litigation is significant: as of December 2023, NBR figures put Tk 23,940 crore as held up in VAT-related cases, with 1,487 VAT appeals pending in the High Court at the year-end.[14]

Alternative dispute resolution

Section 125 allows a taxpayer to apply to a facilitator chosen from an NBR panel to resolve a dispute by consensus. A settlement cannot be challenged in court, an unresolved dispute returns to the ordinary process, and time spent in an unsuccessful ADR does not count against the appeal deadline. Offences and questions of law are excluded.[1] Under rule 99 the application is made in form VAT-17.1 to the Commissioner, the Commissioner (Appeal), the Tribunal or the relevant Division of the Supreme Court, depending on where the dispute sits, and must be resolved within 90 working days of the facilitator receiving the file. Facilitators include retired senior VAT officials and judges and lawyers or accountants with at least seven years' VAT experience.[2] For a refund refused on documentary grounds, ADR is often the fastest route to an agreed figure.

Administration

National Board of Revenue

Sets refund policy, runs e-VAT and the online refund module, and issues general orders.

First decision

VAT Commissionerate

Verifies refund claims, applies set-off under section 70 and approves payment.

First appeal

Commissioner (Appeal)

Hears appeals against orders of an Additional Commissioner or lower officer under section 121.

Second appeal

Customs, Excise and VAT Appellate Tribunal

Hears appeals against Commissioner, Commissioner (Appeal) and Director General orders under section 122.

Questions of law

High Court Division

Hears section 124 appeals on law and writ petitions against unlawful collection.

Drawback

Duty Exemption and Drawback Office

Administers customs drawback and still processes customs and regulatory duty refunds manually.

Common mistakes that delay or defeat a VAT refund Bangladesh claim

Most refund failures are self-inflicted, and the same errors recur across sectors.

  • Gaps in the return history: a single missing or paper-only return blocks the refund under section 70. Jute exporters' stalled claims show how costly this is.[8]
  • Losing track of the six-period clock: credit not claimed in the period of purchase or the following six tax periods is lost under section 46(1)(c), and a missed adjustment cannot be revived by amending the return.[1] [2]
  • Claiming under the wrong section: applying under section 68 when section 69 would allow an immediate refund, or the reverse, without evidence of the 50% tests.
  • Weak export evidence: missing proceeds realisation certificates, UP or UD gaps or unreconciled back-to-back letters of credit.
  • Double recovery: claiming the same tax as VAT credit and as drawback, which invites a section 73(1)(d) determination with interest.
  • Missing the appeal window: treating a refund refusal as an administrative delay rather than an appealable order, and letting the 90 days run.
VAT refund Bangladesh — counsel preparing an appeal against a refused refund
A refused refund is an appealable order with a 90-day clock

What to watch for VAT refund Bangladesh practice in 2026-27

Three developments will shape refunds over the coming year. First, monthly filing under the October 2026 Ordinance resets the rhythm of every claim; use the extension for July to September 2026 to file those periods cleanly before requesting a refund.[10] Second, the NBR's stated aim of a single e-VAT refund channel, including for jute and leather exporters, will remove the last manual routes and make complete online return histories non-negotiable.[8] Third, the cut in appeal pre-deposits to 1% and 2% makes it far cheaper to challenge a claw-back or a reduction than it was before July 2026.[3]

The businesses that recover refunds fastest treat the claim as a file to be built every month, not a request to be made once a year. TRW advises exporters, manufacturers and foreign-owned groups on refund eligibility, section 69 applications, deemed-export documentation, claw-back notices, ADR and appeals. Our tax disputes practice and tax compliance team can review a refund position, or you can contact TRW directly.

Frequently asked questions

Which sections of the VAT Act govern refunds?

Chapter X, sections 68 to 72, of the Value Added Tax and Supplementary Duty Act 2012: carry-forward and refund (68), refund without carry-forward (69), conditions and set-off (70), diplomatic refunds (71) and excess or mistaken payments (72).[1]

How long must excess input tax be carried forward before a refund?

Six tax periods under section 68. After that, a balance above Tk 50,000 is refundable within three months of application, and a smaller balance continues to be carried forward.[1]

Can an exporter get a VAT refund without carrying the balance forward?

Yes. Section 69 allows an immediate refund where 50% or more of turnover is zero-rated, 50% or more of input spending is for zero-rated manufacture, the business regularly generates excess credit, or supplementary duty on export inputs is adjustable.[1]

Which form is used to apply for a VAT refund?

Form VAT-9.1 (Mushak-9.1), the VAT return itself, under rule 52. Advance tax refunds use VAT-4.1 and tourist refunds use a VAT-10.2 certificate.[2]

How is a VAT refund paid now?

Through the e-VAT refund module, which pays approved refunds from Bangladesh Bank directly into the taxpayer's bank account through BEFTN. Automated transfers began on 7 January 2026.[4] [6]

Why might a refund be withheld even if it is valid?

Section 70 bars any refund until all returns up to the current period are filed, and requires the refund to be set off first against outstanding VAT, interest, penalties and fines.[1]

Does the NBR pay interest on a late refund?

Chapter X does not provide for it. Section 127(3) only refunds interest a taxpayer paid on an amount later found not payable.[1]

How is duty drawback different from a VAT refund?

Drawback repays customs duties under sections 36 to 40 of the Customs Act 2023, up to seven-eighths of duty on re-exported goods, and must be claimed within six months of export. DEDO still processes customs duty refunds manually.[8] [9]

How do I challenge a refused VAT refund?

Appeal to the Commissioner (Appeal) within 90 days if an Additional Commissioner or lower officer decided, or to the Appellate Tribunal within 90 days if a Commissioner or Director General decided. ADR under section 125 is an alternative.[1]

What deposit is needed to appeal a refund claw-back?

Since the Finance Act 2026, 1% of the tax demanded, excluding penalty, before the Commissioner (Appeal) or the Appellate Tribunal, and 2% before the High Court Division.[3]

Source register

Primary legal and regulatory sources

Materials checked on 20 October 2026. Confirm the current official text before relying on any provision.

  1. Value Added Tax and Supplementary Duty Act 2012 (Act No. 47 of 2012) — Authentic English Text, SRO No. 440-Law/2025, Laws of Bangladesh
  2. Value Added Tax and Supplementary Duty Rules 2016 — Authentic English Text, National Board of Revenue
  3. PwC Bangladesh, 2026 — Finance Act 2026: Key Amendments
  4. The Daily Star, 10 November 2025 — NBR launches online VAT refund module for faster reimbursement
  5. The Daily Ittefaq (English) / BSS, 10 November 2025 — NBR launches online VAT refund module
  6. The Business Standard, 7 January 2026 — NBR launches automated e-VAT refund system to ease taxpayer hassles
  7. The Daily Star, 8 January 2026 — E-VAT refund launched amid cautious optimism from traders
  8. The Financial Express, 22 July 2026 — NBR plans fully automated VAT refund system
  9. Customs Act 2023 (Act No. 57 of 2023) — Authentic English Text, National Board of Revenue
  10. The Daily Star, 16 October 2026 — Govt restores monthly VAT returns
  11. UNB, 2026 — Businesses get until June 30 to upload paper VAT returns to e-VAT system
  12. High Court Division, Writ Petition No. 2242 of 2023, Pragati Life Insurance Ltd v Bangladesh (6 June 2024)
  13. High Court Division, Writ Petition No. 12872 of 2022, Md Syed Hossain v Customs, Excise and VAT Appellate Tribunal (30 January 2024)
  14. Dhaka Tribune, 28 April 2024 — Case backlog forces revenue disputes to drag on

Related TRW assistance

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TRW advises on VAT refund eligibility, section 69 exporter claims, deemed-export documentation, duty drawback, claw-back notices, ADR and appeals to the Commissioner (Appeal), the Appellate Tribunal and the High Court Division. Explore our tax disputes practice, customs and trade compliance practice, or contact TRW to discuss your matter.

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