Align your cross-border operations with the Income Tax Act 2023. Ensure full compliance with NBR requirements for international transactions and avoid heavy penalties.
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Transfer Pricing regulations in Bangladesh are governed by Chapter XI (Sections 233 to 239) of the Income Tax Act 2023. The National Board of Revenue (NBR) enforces the Arm’s Length Principle (ALP) for all international transactions between associated enterprises.
Compliance is strictly monitored through mandatory disclosures in the tax return and threshold-based TP reports. The NBR's Transfer Pricing Cell is increasingly active in auditing multinational enterprises (MNEs) to prevent base erosion and profit shifting.
Sections 233-239 establish the legal mandate for ALP and provide the NBR with power to adjust prices.
Detailed rules prescribe the five standard OECD methods (CUP, RPM, CPM, PSM, TNMM) for computing ALP.
Taxpayers must submit a 'Statement of International Transactions' with their annual income tax return.
Mandatory for all entities with international transactions.
Every person entering into an international transaction must furnish a Statement of International Transactions along with their annual return of income.
This requirement applies regardless of the transaction volume, ensuring the NBR has visibility into all cross-border related party activities.
Required for transactions exceeding BDT 30 Million.
Entities with aggregate international transactions exceeding BDT 3 Crore (30 Million) must maintain contemporaneous TP documentation.
This study must include functional (FAR) analysis, benchmarking, and the justification for the selected TP method.
Certification required for high-volume transactions.
For transactions exceeding BDT 3 Crore, a report from a Chartered Accountant (as per Section 238) must be submitted to the NBR.
Failure to furnish this report can lead to significant penalties under Section 272 of the Income Tax Act 2023.
Preparation of Local and Master files aligned with NBR standards.
Facilitating independent Accountant’s Reports for NBR submission.
Economic analysis using local and regional comparable data.
Strategic support during TP assessments by the NBR TP Cell.
Our specialized team helps you navigate the intricacies of the new Income Tax Act 2023.
Contact Bangladesh TeamFor further information on transfer pricing please contact:
Principal - Bangladesh Practice