The following incomes shall be deemed to accrued or arises in Bangladesh, namely:-

(a) Any income classified as income from employment irrespective of the place of payment, if any— (i) is acquired in Bangladesh; or

 (ii) if payment is made by the Government or local authority to a Bangladeshi national against the provision of services;

(b) any income accruing or arising, directly or indirectly, from the following sources, namely: –

(i) any permanent establishment situated in Bangladesh;

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

(iii) transfer of any property situated in Bangladesh;

(iv) sell any goods or services electronically to a buyer located in Bangladesh; or

(v) any intangible property used in Bangladesh;

Explanation.—For the purposes of this section,—

(a) the shares of a company resident in Bangladesh, by whomsoever held, shall be deemed to be property situated in Bangladesh; 

(b) any intangible property shall be deemed to be existing   property in Bangladesh, if—

(i) the intangible property is registered in Bangladesh; or

 (ii) where the owner of the intangible property is a non-resident in Bangladesh, if the intangible property is associated with a permanent establishment situated in Bangladesh of the aforesaid non-resident;

(c) in the case of a transfer of shares in a non-resident company in Bangladesh, wherever the transfer of shares takes place, and if the company has any assets in Bangladesh, the amount of the value of the shares transferred to the extent related to   the value of any assets located in Bangladesh shall be deemed to be a transfer of assets located in Bangladesh;

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

(e) any income payable as interest, if any—

(i) is payable by the Government of Bangladesh;

(ii) is payable by a resident, but the following shall not apply, if the loan or money borrowed— (a) Received from outside Bangladesh; and 

(b) is used for the purpose of carrying on a business   outside Bangladesh or for the purpose of deriving income from a source located outside Bangladesh;

(iii) is payable by a non-resident against any loan or money borrowed for the purpose of carrying on a business in Bangladesh or for the purpose of deriving income from any source situated in Bangladesh;

(f) any income received as fees for technical services, if any— (a) is payable by the Government of Bangladesh; or

(b) is payable by a resident person, but the following shall not apply, if the said fee— is payable against services rendered for the purpose of carrying on a business outside Bangladesh; or

(ii) is payable against services rendered for the purpose of deriving income from a source situated outside Bangladesh;

(c) paid by a non-resident as a fee for services undertaken for the purpose of carrying on a business situated in Bangladesh or deriving income from any other source situated in Bangladesh;

(g) Royalty income, viz—              

(a) payable by the Government of Bangladesh;

(b) paid by a resident person, but shall not apply in the    following cases, if the said royalty— is paid in exchange for any property, property or information or services received for the purpose of carrying on a business outside Bangladesh; or

(ii) is paid in exchange for any property, property or information or services received for the purpose of deriving income from a source situated outside Bangladesh; 

(c) payable by a non-resident in exchange for any ownership, property or information or services received used to carry on a business situated in Bangladesh or to derive income from any other source situated in Bangladesh; 

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