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18. Income deemed to accrue or arise in Bangladesh.--
The following income shall be deemed to accrue or arise in Bangladesh, namely:-
(1) any income which falls under the head "Salaries", wherever paid if-
(a) it is earned in Bangladesh; or
(b) it is paid by the Government or a local authority in Bangladesh to a citizen of Bangladesh in the service of such Government or authority;
(2) any income accruing or arising, whether directly or indirectly, through or from-
(a) any business connection in Bangladesh;
(b) any property, asset, right or other source of income in Bangladesh;
or
(c) transfer of capital assets in Bangladesh:
Provided that in the case of a business all the operations of which are not carried out in Bangladesh, only such part of the income as is reasonably attributable to the operation carried out in Bangladesh shall be deemed to accrue or arise in Bangladesh;
(3) any dividend paid outside Bangladesh by a Bangladeshi company;
(4) any income by way of interest payable-
(a) by the Government; o
(b) by a person who is a resident, except where the interest is payable in respect of any debt incurred, or moneys borrowed and used, for the purposes of a business or profession carried on by such person outside Bangladesh or for the purpose of making or earning any income from any source outside Bangladesh; or
(c) by a person who is a non-resident where the interest is in respect of any debt incurred, or moneys borrowed and used for the purposesof a business or profession carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh;
(5) any income by way of fees for technical services payable-
(a) by the Government; or
(b) by a person who is a resident, except where such fees are payable in respect of services utilised in a business or profession carried on by any such person outside Bangladesh or for the purposes of making or earning any income from any source outside Bangladesh; or
(c) by a person who is non-resident where such fees are payable in respect of services utilised in a business or profession carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh.
(6) any income by way of royalty payable-
(a) by the Government; or
(b) by a person who is a resident, except where the royalty is payable in respect of any right, property or information used or services utilized for the purposes of a business or profession carried on by such person outside Bangladesh or for the purposes of making or earning any income from any source outside Bangladesh; or
(c) by a person who is a non-resident where the royalty is payable inrespect of any right, property or information used or services utilized for the purposes of a business or profession carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh.
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