VAT Return Filing in Bangladesh: How to File Mushak 9.1 After the 2026 Changes

VAT return filing Bangladesh: the position on 20 October 2026

VAT return filing Bangladesh businesses do this month runs on rules that changed twice in 2026. The Finance Act 2026 moved every VAT-registered and turnover-enlisted business to a quarterly return from 1 July. Fifteen weeks later, the Value Added Tax and Supplementary Duty (Amendment) Ordinance 2026, gazetted on 14 October, brought back the monthly return, due within 15 days of each tax period.[4] [10] [12] Returns for July, August and September 2026 can be filed online until 25 October without interest or penalty.[11]

This guide covers the return itself: who files Mushak 9.1 and who files Mushak 9.1.1, what goes into each part, how to file and pay through the e-VAT system, what happens when a return is late, and how to correct one. It also covers the 2026 changes and the mistakes that most often lead to a show-cause notice. Rates, registration and the wider VAT system are covered in our companion guide to VAT in Bangladesh.

Summary: Every VAT-registered person files a return for each tax period, which is now again one calendar month, within 15 days of the period's end. Government bodies, banks, insurers and nil-return filers have 20 days. The net tax must be paid before the return is filed, and returns are filed online only. A late return costs a fixed Tk 2,000 penalty plus 1% simple interest a month on unpaid tax. Errors can be corrected by an amended return within four years, but only before an audit or enquiry starts.[1] [2] [5] [10]

Key point: The quarterly return lasted one quarter. The 14 October 2026 Ordinance restores monthly filing, so the October 2026 tax period is due by 15 November 2026. A business that switched its cash planning to quarterly payment must switch back now: under section 45(2) the tax for each month is payable before that month's return is filed.[1] [10] [11]

At a glance

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Table of Contents

Who must file a VAT return in Bangladesh

Section 64 of the Value Added Tax and Supplementary Duty Act 2012 requires every person who is registered or enlisted, or who is required to be registered or enlisted, to file a return for each tax period in the manner the National Board of Revenue (NBR) prescribes.[1] [3] The obligation therefore attaches to the legal status, not to whether any tax is due. A person who should have registered but did not is still in breach of the filing duty, and the five-year limit on tax determination does not protect a person who has failed to file for any tax period.[1]

The rules on VAT return filing Bangladesh law imposes cover four groups. VAT-registered manufacturers, service providers, traders and importers file a VAT return. Businesses enlisted for turnover tax file a turnover tax return. Registered persons with no taxable activity in a month still file, as a nil or zero return. Registered persons who make only exempt supplies must also comply: section 85 imposes a Tk 25,000 penalty for failing to comply with section 64, among other provisions, in relation to exempt supplies.[1]

The Finance Act 2026 widened this population. A BIN or enlistment certificate is now required to open bank and non-bank financial institution accounts, take loans, renew a trade licence, open a mobile financial services merchant account, join a trade association, obtain utility connections and register a vehicle with BRTA.[4] Every new registrant becomes a monthly filer from its first tax period. Our guide to VAT registration for companies in Bangladesh explains how the BIN is obtained.

Which return form applies

Rule 47 of the VAT and Supplementary Duty Rules 2016 prescribes the VAT return in Form Mushak 9.1 and the turnover tax return in Form Mushak 9.2.[2] The 2026 amendments to the Rules split the VAT return in two. Manufacturers, service providers and traders who claim input tax credit continue to file Mushak 9.1. All other VAT-registered persons, including traders who do not claim credit, commercial importers supplying goods under final settlement and traders paying VAT on actual value addition, file Mushak 9.1.1, which does not allow input tax credit to be claimed.[4]

The choice of form is not cosmetic. A trader that files Mushak 9.1.1 cannot recover input VAT through the return, so the form must match the way the business actually accounts for VAT. A business that changes its model during the year, for example by starting to manufacture or to claim credit, should review which form applies before the next return is due.

Who signs and files

A return filed online does not need a physical signature. Where a return is submitted other than online, rule 47(2) requires it to be signed and verified by the registered or enlisted person, by an authorised person or attorney if that person is absent from Bangladesh or unable to sign, by a properly authorised VAT consultant or, for a non-resident, by its agent.[2] In practice, many companies have their VAT consultant prepare the return and a finance officer submit it under the company's e-VAT credentials. The company remains liable for every figure in it.

VAT return filing Bangladesh deadlines after the 2026 Ordinance

The tax period for VAT and supplementary duty is one month of the Gregorian calendar. The Finance Act 2026 substituted the definition in section 2(30) with a single monthly period.[3] That change also removed the special six-month tax period that the Finance Ordinance 2025 had given to construction companies, suppliers and clearing and forwarding agents, and aligned the turnover tax period with the VAT month.[1] [4]

From 14 October 2026, a return is due within 15 days after the end of each tax period. If the fifteenth day is a government holiday, the return may be filed on the next working day. Government, semi-government and autonomous bodies, banks, insurance companies and persons filing a zero return have 20 days.[10] [11] The 20-day concession is not new. It was inserted in July 2025 and carried into the quarterly version of section 64 enacted in June 2026.[1] [3]

The quarterly return of July 2026

The Finance Act 2026, Act No. 96 of 2026, received assent on 30 June 2026 and substituted section 64. The new section 64(1) required a return within 15 days after the end of every three tax periods. Section 64(2) allowed a person to file voluntarily for each tax period on any day of the following period. Section 64(3) let the NBR extend the filing deadline by order, without interest or fine, and section 64(5) let it make electronic filing compulsory.[3] PwC described quarterly filing as the default and monthly filing as optional.[4]

Businesses welcomed the change because it reduced the compliance burden and freed working capital. Economists and former NBR officials warned that it would delay treasury receipts and increase leakage.[7] The Finance Bill had proposed monthly advance deposits based on prior-period liability, but Parliament did not enact that proposal, so payment simply followed the quarterly deadline.[4]

Why monthly returns came back

The Cabinet approved the draft Ordinance on 28 September 2026. It amends section 64 so that a return is due within 15 days after the end of each tax period rather than every three.[9] The Ordinance was published in an extraordinary Gazette on 14 October 2026.[11] An NBR VAT Policy member said many businesses had held back VAT until the end of the three months and that the quarterly cycle had complicated rebates, adjustments and refunds. The Daily Star reported that VAT collection fell about 21% year on year in the first two months of 2026-27.[12]

The reports describe only the change to the deadline in section 64(1). Until the consolidated text is published, businesses should assume that the NBR's powers to extend time and to require electronic filing remain in force, and should file monthly on the 15-day timetable.

The July to September 2026 transition

Many businesses did not file returns for July and August 2026 as monthly filers. On 1 October 2026 the NBR extended the deadline for those periods, and for September where applicable, to 15 October without penalty.[8] On 15 October, after the Ordinance was gazetted, the NBR acted under section 64 and extended the deadline for online returns for the July, August and September 2026 tax periods to 25 October 2026. It did so in the public interest, without interest or penalty, so the e-VAT system could be adjusted.[11] The table below sets out how the rules changed.

What goes into a Mushak 9.1 return

The core of VAT return filing Bangladesh practice is the computation in section 45, which the return reports line by line. Net tax for a tax period equals output tax and supplementary duty payable, less the input tax credit that can be claimed in that period, plus increasing adjustments, less decreasing adjustments.[1] Each figure must come from a document the business can produce in an audit: a tax invoice, bill of entry, credit or debit note, VDS certificate or treasury challan. Section 64 also requires the return to include details of supplementary duty paid.[3]

Output tax and supplementary duty

Output tax is reported from the sales book and the tax invoices issued in the month. Under section 85(1)(g), a person who leaves output tax out of the return faces a penalty of at least 30% and no more than 50% of the tax omitted, on top of the tax and interest.[1] Most findings in a return audit start here: supplies invoiced late, advances not taxed when received, and supplies treated as exempt or zero-rated without the supporting documents.

Input tax credit and the six-period window

Section 46 denies input tax credit if it is not claimed in the tax period in which the inputs were bought or within the following six tax periods. The Finance Ordinance 2025 extended this window from four periods.[1] With monthly returns restored, the window is again six months. Rule 49(1A) adds that a missed credit or rebate cannot be recovered later by amending the return.[2] A purchase book reconciled against supplier invoices every month is the only reliable way to protect input tax credit.

Adjustments, VDS and imported services

Increasing and decreasing adjustments carry credit and debit notes, VAT deducted at source and similar items. A supplier whose VAT has been deducted at source takes a decreasing adjustment for the amount deducted in the return for the relevant tax period or within the following six tax periods.[2] From 2026-27, VAT payable on rent must be deposited by e-payment and reported as an increasing adjustment in the return.[4] VAT on imported services is deposited by the remitting bank through an a-challan, and that challan serves as the tax invoice and, where the service is an input, as the credit document.[4] Our guide to VAT deduction at source covers the withholding rules in detail.

Large invoices and the VAT-6.10 statement

Rule 42 requires a registered or enlisted person to send details of any invoices worth more than Tk 2 lakh, issued or received, to the VAT computer system online in Form VAT-6.10, before or after filing the return for the period.[2] The NBR uses this information to match the supplier's output tax against the buyer's input credit. A mismatch between the two returns is one of the commonest triggers for a query.

Negative net tax, carry forward and refund

If input tax and decreasing adjustments exceed output tax and increasing adjustments, the excess is carried forward and set off in the next six tax periods. After that, a balance of up to Tk 50,000 continues to be carried forward, and a larger balance is refunded within three months of an application.[1] A business deriving at least half its turnover from zero-rated supplies can apply for a refund without first carrying the balance forward.[1] Under rule 52 the refund application is made in Form VAT-9.1 itself.[2] The NBR has said it will not process refund claims unless all the business's returns are in the online system.[6]

How to file a VAT return online through e-VAT

Rule 47(3) lists the places where a return may be lodged, including the NBR's VAT online system, the local VAT office and any place the NBR designates.[2] That choice has now closed for VAT return filing Bangladesh taxpayers. PwC reports that manual returns were completely dispensed with from 1 July 2026 and that VAT returns must be filed online through the designated NBR portal.[5] The Finance Act 2026 also gave the NBR express power under section 64(5) to make electronic filing compulsory.[3] The sequence we use to prepare and file a monthly return is below.

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Pay before you file

Section 45(2) requires the net tax for a tax period to be paid, in the prescribed manner, before the return for that period is submitted.[1] The return records the net tax paid and the treasury challan or electronic payment, and evidence of payment is submitted with the return.[5] Treat the filing deadline as the payment deadline. A return filed on time with tax unpaid is still a default, and interest runs on the unpaid tax from the day after the due date.[1]

Paper returns from earlier periods

Businesses that filed paper returns before July 2026 were required to enter them into the e-VAT system through a "Hard Copy Return Entry" sub-module, under a circular of 5 January 2026. The deadline was extended to 30 June 2026. The NBR warned that closing balances as at May 2026 would be frozen for businesses that missed it, so no later adjustment could be made against them.[6] A business that has not completed this exercise should regularise its e-VAT history before claiming a refund or carrying a balance forward.

Keep the records that support the return

Section 107 requires all accounts, documents and records of the economic activity to be kept for five years.[1] From 2026-27, records kept in ERP or approved VAT software are accepted as valid documents and may be submitted online.[4] The same Finance Act created a penalty of at least the tax evaded and up to double where VAT software supplied by an approved provider is used to tamper with, alter or share data to evade VAT. Both the software provider and the user are liable.[3] [4]

Late VAT returns: penalties, interest and enforcement

A late return has fixed and running costs, and the enforcement steps in VAT return filing Bangladesh cases escalate quickly. The position under the Act and Rules is as follows.

• Penalty: section 85(1)(f) imposes Tk 2,000 for not filing a VAT or turnover tax return on time. The Finance Ordinance 2025 reduced it from Tk 5,000.[1] This is the only penalty under section 85 that can be imposed without first giving the taxpayer a hearing.[1]
• Interest: section 127 charges simple interest of 1% a month on unpaid tax from the day after the due date until payment, capped at 24 months. Arrears of VAT deducted at source carry 2% simple interest every six months instead.[1] Interest is payable in addition to any penalty or fine.[1]
• Notice: under rule 57A, the VAT officer issues a notice in Form VAT-11.1 for late submission. If the return is not filed within 21 days of that notice, the officer may begin a tax determination under section 73 by preliminary notice.[2]
• BIN lock: if the return is still not filed, the NBR may temporarily lock the BIN in the VAT online system. This stops imports, exports and supplies involving VAT deducted at source. The lock lifts automatically within two days of the return being filed.[2]

Permission to file late

Section 65 lets the Commissioner permit a late return, but the permission cannot extend the date for paying tax by more than one month and does not remove interest.[1] Under rule 48, the application is made in Form VAT-9.3 within seven days after the end of the tax period, giving proper reasons. The Commissioner must decide within seven days, failing which approval is deemed. If approval is given and the return is filed within the approved time, no section 85(1)(f) penalty is charged, but interest is still payable.[2] Without prior approval, both penalty and interest apply.[2]

Temporary closure and NBR extensions

Section 85(4a) waives the late-return penalty for the interim tax periods where a business has closed temporarily because it made no supplies and reopens later.[1] The NBR can also extend the deadline for everyone. Section 64 as substituted in 2026 allows it to do so by order, in the public interest, without interest or fine, which is the power it used for the July to September 2026 returns.[3] [11]

Why a missed return costs more than Tk 2,000

The fixed penalty is small. The real exposure is what a missed return opens up. Failure to file is an independent ground for a show-cause notice under section 73(1)(b), and the officer then determines the tax on the information available.[1] More importantly, the five-year limit on tax determination in section 73(3) does not apply where a registered person has not filed a return for a tax period.[1] An unfiled month can therefore be reopened long after the periods around it have closed.

A consistent filing record also has practical value. Rule 116 makes a taxpayer who files every return on time in a financial year eligible for an Honour Card. It also allows the Commissioner to ask licensing authorities not to issue licences, permits or registrations to a taxpayer with arrears unless it produces a valid tax clearance certificate.[2]

Amending a VAT return in Bangladesh

Corrections are part of VAT return filing Bangladesh compliance, not an admission of fault. Section 66 lets the Commissioner permit a taxpayer to file an amended return to correct clerical mistakes or omissions, or a revised return, within the time and conditions prescribed. The NBR may define when an amendment that produces a decreasing adjustment can be filed without penalty.[1] Rule 49 sets out how this works.

Grounds and time limit

A filed VAT or turnover tax return may be amended for a clerical error, for an underpayment or overpayment caused by a calculation error, or for any other error except forgery.[2] Rule 49(1A) excludes everything else. In particular, a return cannot be amended to recover a decreasing adjustment or rebate that was not taken within the prescribed period.[2] The application must be made within four years of filing the original return. It cannot be made once the VAT authority has started an audit or enquiry, or has otherwise discovered the error.[2]

Procedure

The taxpayer applies immediately after identifying the error, either online through the return for the relevant tax period or, in other cases, on Form VAT-9.4 to the Commissioner. The application must explain the error and why the amendment is needed in detail.[2] Where the amendment reduces net tax, the Commissioner must decide within 30 days, and an application not decided in that time is deemed approved.[2]

Consequences: more tax or less

If the amendment increases net tax and the request is made before an audit notice, the taxpayer pays the shortfall with interest under section 127, and no penalty or fine may be imposed because of the amendment.[2] Section 85(2a) gives similar protection in the Act: where tax was underpaid by mistake or misrepresentation and the final tax is later paid with interest, no penalty is imposed.[1] If the amendment reduces net tax, a VAT registrant takes a decreasing adjustment in the tax period the Commissioner sets. A turnover taxpayer deducts the amount from turnover tax payable, and a withholding entity receives a refund.[2]

The lesson is timing. A voluntary correction made before an audit notice costs interest only. The same error found in an audit can attract a penalty of 30% to 50% of the tax, and the right to amend is lost.[1] [2] Businesses should run a monthly reconciliation and a deeper review before the year-end audit cycle, and correct errors as soon as they are found.

Complete, additional or alternative returns

Separately, section 67 lets the Commissioner, by notice, order a person to file a complete, additional or alternative return for a tax period, including where no original return was filed.[1] Under rule 50, a return filed under such an order replaces any regular return for that period. Failure to comply within the time in the order is treated as a failure under section 85(1)(f).[2]

Errors in the return: the penalty ranges in 2026

Section 85 grades penalties by the type of error, and the 2026 changes softened the ranges that matter most for VAT return filing Bangladesh businesses. All are payable in addition to tax, interest and any fine, and all except the late-return penalty require a hearing first.[1]

• Omitted output tax: at least 30% and no more than 50% of the output tax not included.[1]
• Excess input tax credit: the Finance Act 2026 reduced the range for irregular credit and adjustments from between half and the full amount to between 30% and 50%.[4]
• Inflated decreasing or reduced increasing adjustments: at least 30% and no more than 50% of the amount, under the row substituted by the Finance Act 2026.[3]
• Wilful evasion: between half and the full amount of tax evaded.[1]
• Software tampering and counterfeit stamps: new rows impose at least the evaded tax and up to double.[3]

A penalty does not prevent a criminal case on the same facts, so a return found to contain deliberate false statements can expose directors as well as the company.[1]

When the VAT office challenges a return

A return the officer considers inaccurate, a return not filed, unpaid tax and a wrongly obtained refund are each grounds for a preliminary show-cause notice under section 73. The penalty can be included in the same notice. If the taxpayer objects in writing, it must be heard, and the final determination must be made within 120 days of the objection. Payment must be allowed at least 15 working days after service.[1]

The determination can be appealed to the Commissioner (Appeals) within 90 days, with a possible further 60 days for obvious reasons for delay. A further appeal lies to the Customs, Excise and VAT Appellate Tribunal.[1] The Finance Act 2026 cut the pre-deposit from 10% to 1% before the Commissioner (Appeals) and the Tribunal, and to 2% before the High Court Division.[4] Section 125 also offers alternative dispute resolution through a facilitator.[1] Arrears can be paid in instalments with the Commissioner's permission over up to 18 months.[1] The full appeal route is set out in our guide to VAT in Bangladesh, and TRW's tax disputes practice handles show-cause replies and appeals.

Common Mushak 9.1 mistakes and how to avoid them

Most VAT return filing Bangladesh problems we see are not about the law. They are about process. These are the errors that most often turn a routine return into a demand.

• Staying on a quarterly cycle: the October 2026 return is due by 15 November 2026. Treat every month from October as a separate filing and payment.[10]
• Filing without paying: section 45(2) requires the net tax to be paid before the return is filed, and interest runs from the due date.[1]
• Using the wrong form: a trader claiming credit on Mushak 9.1.1, or a non-credit trader on Mushak 9.1, produces a return the system or officer will query.[4]
• Losing input tax credit: credit not claimed within six tax periods is lost and cannot be recovered by amendment.[1] [2]
• Ignoring VDS certificates: decreasing adjustments for VAT deducted at source must be taken within the same six-period window.[2]
• Skipping nil returns: a month with no activity still needs a return, and an unfiled month is outside the five-year limit.[1]
• Leaving e-VAT history incomplete: refunds depend on all returns being in the online system.[6]
• Correcting too late: once an audit or enquiry starts, the right to amend is lost.[2]

Mismatches are a separate risk. The NBR compares the VAT-6.10 statements and VDS certificates of both parties to a transaction.[2] A finance team that agrees its figures with major suppliers and customers before filing will avoid most queries.

VAT return filing Bangladesh compliance calendar for 2026-27

For a business on the standard 15-day deadline, the next dates follow directly from section 64 as amended by the Ordinance: the tax period is the calendar month, and the return and payment are due by the fifteenth day of the next month, or the next working day if that day is a holiday.[3] [10]

• 25 October 2026: last day to file returns in e-VAT for July, August and September 2026 without interest or penalty.[11]
• 15 November 2026: return and payment for October 2026.
• 15 December 2026: return and payment for November 2026.
• Each month thereafter: the fifteenth, or the twentieth for government bodies, banks, insurers and nil-return filers.[10]

Two internal dates matter as much as the statutory ones. Close the purchase and sales books, and reconcile VDS certificates, by the fifth working day of the month. Apply for permission on Form VAT-9.3 within seven days after the end of the tax period if a late return is unavoidable.[2]

What to watch for VAT returns in 2026-27

Three questions will shape VAT return filing Bangladesh practice over the rest of the fiscal year. The first is whether Parliament enacts the Ordinance as an Act, amends it or lets it lapse. The second is the consolidated text of section 64, including whether optional early filing and the electronic-filing power survive unchanged.[3] The third is how the NBR handles credits, VDS adjustments and refunds that straddle the quarterly and monthly regimes. The NBR's own explanation for the reversal points to exactly those complications.[12]

For most businesses the answer is simple: file monthly, pay before filing, reconcile every month and correct errors before an audit notice arrives. TRW's tax compliance practice reviews VAT return processes, prepares amended returns and responds to VAT-11.1 notices and show-cause notices. Corporate groups should read this guide with our overview of tax law in Bangladesh. You can also contact TRW directly.

Frequently asked questions

When is the VAT return due in Bangladesh now?

For VAT return filing Bangladesh purposes, within 15 days after the end of each monthly tax period, or the next working day if the fifteenth is a government holiday. This follows the Amendment Ordinance gazetted on 14 October 2026.[10] [11]

Is the quarterly VAT return still available?

No. The Finance Act 2026 introduced it from 1 July 2026, but the Amendment Ordinance 2026 restored filing for each tax period.[3] [10]

What is the deadline for the July to September 2026 returns?

The NBR extended it to 25 October 2026 for online returns, without interest or penalty.[11]

Who gets 20 days instead of 15?

Government, semi-government and autonomous bodies, banks, insurance companies and persons filing a zero return.[1] [10]

What is the difference between Mushak 9.1 and Mushak 9.1.1?

Mushak 9.1 is for manufacturers, service providers and traders who claim input tax credit. Mushak 9.1.1 is for other registered persons, such as traders not claiming credit, and does not allow credit claims.[4]

Can I still file a paper VAT return?

No. Manual returns were dispensed with from 1 July 2026, and returns are filed online through the NBR's e-VAT portal.[5] [6]

Do I have to file if I made no sales in the month?

Yes. Every registered or enlisted person files for each tax period, and a nil return has 20 days. Failing to file also removes the five-year limit on tax determination for that period.[1]

What is the penalty for a late VAT return?

Tk 2,000 under section 85(1)(f), plus simple interest of 1% a month on unpaid tax for up to 24 months under section 127.[1]

How long do I have to amend a VAT return?

Four years from filing the original return, provided no audit or enquiry has started and the error has not otherwise been discovered.[2]

Will I be penalised if my amended return shows more tax?

Not if the request is made before an audit notice and the shortfall is paid with interest. Rule 49(6) and section 85(2a) bar a penalty in that case.[1] [2]