18. Income deemed to accrue or arise in Bangladesh.--

18. Income deemed to accrue or arise in Bangladesh.--

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

(1) any income which falls under the head "Salaries", wherever paid if-

(a) it is earned in Bangladesh; or
(b) 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;

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

(a) any business connection in Bangladesh;
(b) any property, asset, right or other source of income in Bangladesh;
or
(c) transfer of capital assets in Bangladesh:

Provided that in the case of a business all the operations of which are not  carried  out  in  Bangladesh,  only  such  part  of  the  income  as  is reasonably  attributable  to  the operation  carried  out  in  Bangladesh shall be deemed to accrue or arise in Bangladesh;

(3) any dividend paid outside Bangladesh by a Bangladeshi company;
(4) any income by way of interest payable-

(a) by the Government; o
(b) by a person who is a resident, except where the interest is payable in respect of any debt incurred, or moneys borrowed and used, for the purposes of a business or profession carried on by such person outside Bangladesh or for the purpose of making or earning any income from any source outside Bangladesh; or
(c) by a person who is a non-resident where the interest is in respect of any debt incurred, or moneys borrowed and used for the purposesof a business or profession carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh;

(5) any income by way of fees for technical services payable-

(a) by the Government; or
(b) by a person who is a resident, except where such fees are payable in respect of services utilised in a business or profession carried on by any such person outside Bangladesh or for the purposes of making or earning any income from any source outside Bangladesh; or
(c)  by  a  person  who is  non-resident  where  such fees  are  payable  in respect of services utilised in a business or profession carried on by such person in Bangladesh or for the purposes of making or earning any income from any source in Bangladesh.

(6) any income by way of royalty payable-

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

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

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