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United States - Bangladesh tax treaty

A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.

Signed

2004-09-26

Effective

2007-08-07

Articles seeded

6

Withholding snapshot

Dividends

Individual rate: 15% · Corporate rate: 10%

The 10 percent corporate rate generally depends on direct ownership of at least 10 percent of the voting stock of the dividend payer. Article-level review is important because Bangladesh domestic withholding rules interact with the treaty in nontrivial ways.

Interest

Rate: 10%

IRS Treaty Table 1 reflects a general 10 percent ceiling on qualifying interest, with exemptions for certain government and central-bank interest. Beneficial ownership and documentation matter for reliance.

Royalties

Rate: 10%

The Bangladesh treaty applies a general 10 percent ceiling on royalties, with article-level review controlling for software, patent, and copyright classification.

Permanent establishment

Construction threshold: more than 183 days

Dependent-agent analysis remains important where a person habitually exercises authority to conclude contracts on behalf of the enterprise under the treaty wording.

Other treaty flags

Pensions: split
Protocols: None seeded
Exchange of information: Yes
Student article: Yes
Teacher article: No

Pension treatment is article-specific, with government-service pensions and private pensions handled under distinct provisions.

Seeded article summaries

Article 4

Residence

Defines treaty residence and is the gateway to any reduced withholding or treaty protection.

Residence under the Bangladesh treaty matters particularly for U.S. consultants and contractors with intermittent Bangladesh presence. Tie-breaker analysis controls where domestic rules would otherwise produce dual residence.

Article 5

Permanent Establishment

Sets the business-presence threshold that permits source-country taxation of business profits.

The treaty includes a 183-day threshold for certain construction and supervisory projects and a service-PE provision. These thresholds can create source-country exposure earlier than under classic OECD-style treaties.

Article 7

Business Profits

Generally reserves business profits to the residence state unless a permanent establishment exists in the other state.

This article matters for U.S. firms operating in Bangladesh's growing services and garment sectors. The PE thresholds in Article 5 should be read carefully before assuming Article 7 protection.

Article 10

Dividends

Provides treaty limits on source-country dividend withholding in qualifying cases.

The dividend article's 10 percent and 15 percent ceilings are the quick snapshot, but ownership thresholds and Bangladesh domestic withholding interactions control the practical outcome.

Article 11

Interest

Limits source-country withholding on qualifying interest.

The treaty does not eliminate interest withholding outright, but the 10 percent ceiling provides meaningful reduction from Bangladesh's domestic rates in many cases. Beneficial-ownership documentation drives practical reliance.

Article 12

Royalties

Limits source-country withholding on qualifying royalties.

The royalty article applies a 10 percent ceiling, which is meaningful relative to domestic Bangladesh rates but still requires careful category-by-category analysis for software and know-how payments.

Official text

Other treaties involving these jurisdictions

Computed from the cross-reference graph. Links open the related entity on this site.

Primary sources

Important disclaimer

This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.