Transfer Pricing & International Tax
Arm’s-length benchmarking, Chartered Accountant Transfer Pricing certificates, Statement of International Transactions, and DTAA advisory.
Service Overview
Foreign subsidiaries, joint ventures, and Bangladeshi groups transacting with overseas associated enterprises face strict Transfer Pricing scrutiny from the NBR Transfer Pricing Cell. Where international transactions exceed the statutory threshold (BDT 3 Crore in an income year), taxpayers must maintain contemporaneous Transfer Pricing documentation and submit a Statement of International Transactions alongside a report from a Chartered Accountant.
M.S. Salekin & Co. advises multinational subsidiaries, sourcing offices, and cross-border service providers on Transfer Pricing compliance, Double Taxation Avoidance Agreement (DTAA) benefits, and withholding tax on outward remittances.
Who This Service Is For
- Bangladesh subsidiaries and joint ventures transacting with foreign parent or sister companies
- Companies paying royalty, technical know-how, management fees, or software license fees abroad
- Export/import enterprises buying from or selling to related overseas entities
- Foreign contractors, project offices, and expatriate employers navigating Permanent Establishment (PE) and DTAA rules
What We Do & Key Deliverables
Every engagement is scoped in writing with clear outputs reviewed by Mohammad Sirajus Salekin, FCA.
Transfer Pricing Study & Local File Documentation
Functional analysis (FAR — Functions, Assets, Risks), selection of the Most Appropriate Method (MAM), and economic benchmarking to substantiate arm’s-length pricing.
Accountant’s Report & Statement of International Transactions
Verification and issuance of the statutory Chartered Accountant’s certificate and preparation of the Statement of International Transactions for corporate tax return filing.
Outward Remittance & DTAA Withholding Tax Advisory
Advisory on withholding tax rates under the Income Tax Act 2023 read with applicable Double Taxation Avoidance Agreements (DTAAs), and obtaining NBR tax certificates for bank remittances.
Documents Typically Required
We share a customized document request list upon engagement onboarding. Core records typically include:
- Inter-company agreements (supply, service, royalty, management fee, or loan agreements)
- Ledger breakdown and invoices of all international transactions with Associated Enterprises during the income year
- Group organizational chart showing ownership linkages and associated relationships
- Group Master File / global Transfer Pricing policy and segmented financial statements
- Tax Residency Certificate (TRC) of the foreign recipient (for DTAA treaty claims)
Typical Engagement Timeline
Actual turnaround depends on transaction volume, readiness of primary records, and regulatory authority processing queues.
Associated Enterprise & Transaction Scoping
Identifying covered international transactions and assessing the BDT 3 Crore statutory threshold.
FAR Analysis & Benchmarking Study
Conducting functional interviews, selecting the pricing method, and compiling the TP study report.
TP Certificate Issuance & Return Filing
Issuing the Chartered Accountant certification prior to the corporate tax return deadline.
Relevant Bangladesh Laws & Authorities
Income Tax Act 2023 (Transfer Pricing Chapter)
Mandates arm’s-length pricing, TP documentation, and Accountant’s Report for international transactions > BDT 3 Crore
NBR Transfer Pricing Cell & International Tax Wing
Conducts Transfer Pricing audits and administers bilateral DTAAs
Bangladesh Bank Foreign Exchange Guidelines
Regulates outward remittances for royalties, technical fees, and dividends
Frequently Asked Questions — Transfer Pricing & International Tax
Let’s talk about what comes next.
Schedule a confidential initial consultation with Mohammad Sirajus Salekin, FCA (Fellow Chartered Accountant (FCA), Member of ICAB) to discuss your organisation’s statutory requirements or personal tax filing.