DT3140 - DT: Bangladesh: double taxation agreement, Article 21: Miscellaneous provisions

(1) Where under any provision of this Convention income is relieved from tax in a Contracting State and, under the law in force in the other Contracting State, an individual, in respect of the said income, is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State, and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first-mentioned State shall apply only to so much of the income as is remitted to or received in that other Contracting State.

(2) The provisions of section 23A of the Bangladesh Income tax Act relating to the imposition of additional tax on undistributed profits shall not apply to the income of a company, being a resident of Bangladesh, more than 50 per cent of the voting shares of which are owned by a company which is a resident of the United Kingdom and quoted on a stock exchange, if the undistributed profits of the first-mentioned company are wholly or mainly retained for the purpose of industrial development in Bangladesh.

(3) Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State.

(4) The provisions of Bangladesh law which provide for a rebate of tax to be given in certain circumstances to a public company shall not be construed as being inconsistent with the provisions of Article 23.