The following income shall be deemed to accrue or arise in Bangladesh, namely:—

(a) any income which falls under the head “Income from employment”, wherever paid if—

(i) it is earned in Bangladesh; or

(ii) 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;

(b) any income accruing or arising, whether directly or indirectly, through or from-

(i) any permanent establishment in Bangladesh;

(ii) any property, asset, right or other source of income, including intangible property, in Bangladesh; or

(iii) the transfer of any assets situated in Bangladesh;

(iv) the sale of any goods or services by any electronic means to purchasers in Bangladesh; or

(v) any intangible property used in Bangladesh;

Explanation.— For the purpose of this section—

(a) the shares of any company which is a resident in Bangladesh, whoever holds it, shall be deemed to be property in Bangladesh;

(b) intangible property shall be deemed to be property in Bangladesh if-

(i) intangible property is registered in Bangladesh; or

(ii) owned by a person that is not a resident of Bangladesh but has a permanent establishment in Bangladesh to which the intangible property is attributed;

(c) the transfer of any share in a company that is not a resident of Bangladesh shall be deemed to be the transfer of an asset situated in Bangladesh, wherever such transfer may be made, to the extent that the value of the share transferred is directly or indirectly attributable to the value of any assets in Bangladesh;

(d) any dividend paid outside Bangladesh by a Bangladeshi company;

(e) any income by way of interest, if payable—

(i) by the Government of Bangladesh; or

(ii) by a person who is a resident, except for the following cases where the debt or borrowed money—

(1) received from outside Bangladesh; and

(2) used, for the purpose of a business carried on outside Bangladesh or for the purpose of earning any income from any source outside Bangladesh;

(iii) by a person who is a non-resident where the debt incurred, or moneys borrowed and used for the purposes of a business carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh;

(f) any income by way of fees for technical services, if payable—

(i) by the Government of Bangladesh; or

(ii) by a person who is a resident, except for the following cases, if such fees—

(1) are payable in respect of services utilized in a business carried on outside Bangladesh; or

(2) are payable for the purposes of making or earning any income from any source outside Bangladesh;

(iii) by a person who is a non-resident where such fees are payable in respect of services utilized in a business carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh;

(g) any income by way of royalty payable—

(i) by the Government of Bangladesh; or

(ii) by a person who is a resident, except where the royalty—

(1) is payable in respect of any right, property or information used or services utilized for the purposes of a business carried outside Bangladesh; or

(2) is payable for the purposes of earning any income in exchange of any right, property or information or services received from any source outside Bangladesh;

(iii) by a person who is a non-resident where the royalty is payable in respect of any right, property or information used or services utilized for the purposes of a business carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh;

(h) insurance or reinsurance premiums accrued or payable by a resident or non-resident to insure against any risk within Bangladesh.