Double Taxation Avoidance Agreement & method of determining notional income

Today I am going to discuss about double taxation which is a very common problem faced by a resident  or non resident when comes from abroad .  If the country has agreement with Bangladesh , the taxpayer ( assesse) may not pay tax again under some conditions . In fact , to develop economy Govt. of many countries sign many treaties with each other. It relieves them from discrimination and misunderstanding. It develops mutual understanding and friendship. Details of it is available here. 

Double Taxation Avoidance Agreement (Sec. 144 read with 7th Schedule) :

The Bangladesh model of Agreement on Avoidance of Double Taxation consists of 29 Articles  . Bangladesh has agreement with more or less 32 countries.

name of continent	country
Asia	India, Sri Lanka, Pakistan, China, Japan,     Singapore, Korea, Philippines, Thailand, Vietnam, Myanmar, Malaysia, Indonesia, Mauritius, Saudi  Arabia, U A E, Oman, Turkey
Europe	UK, Norway, Sweden, France, Germany , Netherlands, Italy, Denmark ,Romania, Belgium , Poland, Switzerland
North America	Canada, USA

Requirements  

                       Tax clearance certificate from where he came

method of determining the amount of notional income of non resident

Sometimes non resident taxpayer may have profit/ gain/ income in Bangladesh . But at that time he may be in a foreign country. Therefore, it is necessary to address the issue here.

     Rule-35 read with rule-34 prescribes the method of determining the amount of notional income in respect of which the non resident may be charged under section 104.

who will charge ?

                         D C T

when?

                       actual amount of profit/ gain/  income accruing or arising in Bangladesh to non resident Bangladeshi cannot be determined

source

                         business connection, any property ,any asset in Bangladesh

amount :

                   to be determined by DCT on the basis of percentage of turnover accruing or arising considered reasonable or on profits computed under provisions