Newsletter

BUILD organised a high-level dialogue today titled “Duty-Free Import of Raw Materials beyond Bonded Warehouse Facility” to address implementation challenges and propose critical reforms for the recently announced Statutory Regulatory Order (SRO) 384/2025. The event, held at the BUILD conference room, brought together policy experts, government officials, and private-sector leaders to identify strategies to enhance the export competitiveness of non-bonded and small-scale exporters.

In the keynote presentation, Md Nooruzzaman, Senior Research Associate, highlighted that non-bonded exporters will be able to import raw materials duty-free against a 100% bank guarantee. He informed the session that this would be difficult for them to afford, as the guarantee will be encashed after the export proceeds are realised, limiting their cash flow. To qualify for this facility, exporters must ensure a minimum of 30% value addition and maintain mandatory Value Added Tax (VAT) compliance through regular online submissions. However, the facility is currently restricted to only eight sectors, including furniture, electronics, and light engineering, which limits significant export potential.

By comparing Bangladesh’s regime with international best practices, such as the duty-suspension model in Vietnam and the deferred-duty model in India, the study advocates adopting more flexible financial instruments to reduce exporters’ burdens. Key recommendations include aligning SRO 384 with the upcoming Import Policy Order 2025–28, replacing bank guarantees with alternative instruments, such as sponsor guarantees, and removing sectoral restrictions to encourage broader export diversification. Furthermore, the study emphasises the urgent need for full automation and the integration of the Automated System for Customs Data (ASYCUDA) and the Integrated VAT Administration System (iVAS) systems to streamline the export process and enhance global competitiveness.

The working session was moderated by Dr Wasel Bin Shadat, Research Director, BUILD. Mohammad Naziur Rahman Miah, First Secretary, NBR, lauded the dialogue organised by BUILD and stated that formulating SRO 384 was a challenging task; he noted it is not a fixed document and will be updated as requirements evolve. He added that eight sectors have been listed due to their interest, and the list will be extended if other sectors show interest. Referring to the abolition of the need for coefficients for bonded warehouse (BWH) exporters and for utilisation declaration (UD) and utilisation permission (UP), he informed that NBR has opted to automate these services. About 83% of the UP is presently automated, and the Bangladesh Garment Manufacturers and Exporters Association (BGMEA), Customs, and other relevant organisations are now integrated, which will gradually improve the situation.

Md Shahidulla, senior deputy secretary, Bangladesh Plastic Goods Manufacturers and Exporters Association (BPGMEA), noted that the local VAT authority is the controlling point, and those willing to benefit from this system must be Import Registration Certificate (IRC) and Export Registration Certificate (ERC) holders, distinct from Customs Bond Commissionerate (CBC) licence holders. He referred to the full operationalisation of the Duty Exemption and Drawback Office (DEDO) to provide support to exporters; however, exporters countered that, through DEDO, 100% duty drawback has never occurred.

Several industry leaders proposed alternatives to the current system. Saifur Rahman, Vice President of the Bangladesh Stainless Steel Pipe Manufacturers Association, emphasised the need to ensure ease of doing business for export diversification and highlighted that the government needs to focus on dynamic decision-making. He recommended that Bangladesh follow the Chinese model, in which warehouses are built through a public–private partnership (PPP). In view of this, a committee is working at NBR, and BUILD could be included to work on this. Similarly, M. S. Siddiqui, CEO of Bangla Chemical, recommended that revenue policies be adopted by independent bodies rather than concentrating all power within NBR. Criticising the 100% bank guarantee, he said it is not a global practice, emphasising that the market should decide which products are exported and warning against forcibly adding products to the negative list.

Sector-specific recommendations were also raised. Md Abdur Rauf, CEO of the Bangladesh Furniture Exporters Association, urged the government to place greater emphasis on value-addition criteria rather than UP, UD, and bank guarantees for export facilitation. Shoaib Hasan, former Vice President of the Bangladesh Agroprocessors Association (BAPA), urged the government to allow a 30% duty-free import of raw materials based on export performance, noting that if this incentive is granted, export volume could be doubled. Shankar Kumar Roy, Executive Director of the Bangladesh Cement Manufacturers Association, urged the inclusion of the cement sector in the SRO’s positive list due to its significant domestic use.

Regarding financial and time constraints, Mainul Islam, Deputy Manager at the Small and Medium Enterprise (SME) Foundation, urged NBR to align with the Ministry of Industries in formulating policies. He recommended including the priority sectors of the National Industrial Policy 2022 and the Product of the Year, as declared annually by the Ministry of Commerce, in the positive list, adding that the SME Foundation could create a fund for sponsor guarantees for SME exporters, if legally permitted. Sharif Nawrin Akter, Assistant General Manager, Leathergoods and Footwear Manufacturers and Exporters Association of Bangladesh (LFMEAB), recommended that bank guarantee realisation be carried out in phases. She argued that the current nine-month time limit for export (extendable by three months) is too short and should be at least two tax periods, given the possibility of order cancellations or delays in proceeds realisation.

Summing up, Ferdaus Ara Begum, CEO of BUILD, informed that BUILD has taken full notes of the discussion and will prepare a report to share with NBR for necessary reforms to the SRO, so that SMEs can benefit from the policy, reduce dependence on a single product, and promote export diversification.

The 39th trustee board meeting of BUILD officially appointed Abul Kasem Khan as the Chairperson of BUILD for the 2026–27 tenure. Khan, an esteemed member of the BUILD trustee board since 2020, assumed this leadership responsibility following a formal resolution by the board in accordance with the relevant articles of the BUILD deed of trust.

Nominated by the DCCI, Khan currently serves as the vice chairman of A. K. Khan & Company Limited and the managing director of A. K. Khan Telecom Limited. He served as president of DCCI for three terms in 2010, 2017, and 2018.

The trustee board also welcomed several distinguished representatives to its membership, including Taskeen Ahmed, President of DCCI; Kamran T. Rahman, President of the MCCI; Md Motahar Hossan, Administrator of the CCCI; Dr A. K. M. Asaduzzaman Patwary, Acting Secretary General, DCCI; and Farooq Ahmed, Secretary General, MCCI.

As a premier PPD platform supported by DCCI, MCCI, and CCCI, BUILD has been serving as the secretariat to the PSDPCC at the Prime Minister’s Office since 2011. The organisation remains committed to advancing seven thematic areas of PPD, with a primary strategic focus on trade facilitation and optimising the investment climate. The mandate of BUILD is to identify regulatory, procedural, and policy barriers affecting trade, investment, and industrial growth in the country. It conducts evidence-based research and submits policy recommendations to relevant ministries, departments, and regulatory authorities to enhance the private sector’s competitiveness. BUILD, as a national PPD platform, facilitates structured consultations between government and private-sector stakeholders.

BUILD formally signed a service contract with the Department of Foreign Affairs and Trade (DFAT) of the Australian High Commission in Bangladesh on 15 December 2025. The agreement marks the launch of a flagship research project aimed at enhancing the export competitiveness of small and medium-sized enterprises (SMEs) in Bangladesh.

The project, titled “Study and National Conference on SME Competitiveness and Export Growth”, seeks to generate robust empirical evidence to inform policy reforms. These reforms aim to expand SME access to bonded warehouse (BW) facilities—one of the most critical trade facilitation tools in the country, which is currently dominated by large, 100% export-oriented firms, particularly within the ready-made garments (RMG) sector.

Although SMEs account for nearly 25 per cent of Bangladesh’s gross domestic product (GDP) and employ millions nationwide, their participation in exports remains limited. A key structural barrier has been restricted access to bonded warehouse facilities, which allow the duty‑free import of raw materials for export production. Recent regulatory changes, including the Bonded Warehouse Licensing Rules 2024, have further tightened eligibility criteria. This has disproportionately affected SMEs and partial exporters operating outside economic zones and high‑tech parks.

Implemented in core partnership with the SME Foundation, the DFAT‑supported study will examine how exclusion from bonded warehouse facilities raises production costs for SMEs, undermines their global competitiveness, and limits export diversification. This is an increasingly urgent concern as Bangladesh prepares for its graduation from the status of a least developed country (LDC) in 2026.

The research will also assess the effectiveness of recent fiscal and policy measures, including the financial year (FY) 2025–26 budget proposals regarding central bonded warehouses (CBWH) and free trade zone (FTZ)‑based bonded facilities. Furthermore, it will identify practical governance mechanisms—such as risk‑based audits, quota systems, and digital monitoring—to ensure SME inclusion while safeguarding government revenue.

Key outputs of the project will include a comprehensive research report, a policy options matrix, stakeholder validation workshops, and a national dissemination conference. This conference will bring together government agencies, private-sector leaders, development partners, and civil society organisations.

By supporting this initiative, DFAT reaffirms Australia’s commitment to inclusive economic growth, trade facilitation, and private‑sector development in Bangladesh. The study’s findings are expected to provide policymakers with an evidence-based roadmap for reforming bonded warehouse policies, reducing structural biases, and enabling SMEs to play a more dynamic role in Bangladesh’s export economy in the post-LDC era.

The Ministry of Commerce (MoC), in collaboration with the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH under the Sustainability in the Textile Sector (STILE‑II) project, convened a high‑level policy discussion on product traceability on 30 November 2025 at the MoC conference room, chaired by its secretary, Mahbubur Rahman.

BUILD provided thematic and research support for this activity under the STILE‑II project of GIZ. In her keynote presentation, Ferdaus Ara Begum, chief executive officer of BUILD, highlighted that strengthening product traceability has become a critical national priority as global markets, particularly the European Union, have introduced new requirements linked to the circular economy, Digital Product Passports (DPP), responsible business conduct, and sustainability disclosures. With 92 per cent of Bangladesh–EU trade concentrated in the RMG sector, Bangladesh must align its policies with EU Green Deal requirements by approximately 2030.

The keynote underscored significant challenges, including data validation, interoperability, institutional coordination, and initial compliance costs. Drawing on international experiences from Vietnam, China, Japan, Korea, and India, she noted that public–private co‑investment has been central to building robust traceability ecosystems. She emphasised the need for a national traceability strategy supported by sector‑specific measures, adding the requirement for a jhut sector directory, institutional frameworks for traceability, expanded data infrastructure, and the introduction of green financing options to help Bangladesh’s industry implement traceability solutions.

Mahbubur Rahman, secretary of the MoC, referring to examples from Germany, emphasised the urgent need to establish a digital platform for data exchange and, in that respect, requested support from development partners. He also initiated the drafting of a national traceability strategy, which can include plans for sector‑specific traceability pilots under the leadership of the MoC and with technical support from GIZ.

Additionally, he inaugurated the activities of a multi-stakeholder dialogue platform, chaired by the export wing of the MoC and comprising members from both the public and private sectors. This platform will convene policy discussions around key sustainability topics, including the proposed traceability policy. He advised the Export Promotion Bureau (EPB) to initiate a project to explore data transparency and governance issues by extending support to exporters in obtaining unique IDs, building on the EPB’s experience with implementing REX.

Representatives from the Bangladesh Garment Manufacturers and Exporters Association (BGMEA), the Bangladesh Knitwear Manufacturers and Exporters Association (BKMEA), and the leather sector shared updates on ongoing sector‑specific pilot initiatives.

BGMEA Director Sheikh H. M. Mustafiz stated that RMG entrepreneurs are facing difficulties due to data requirements from various quarters, including brands, buyers, and private consultants. It is challenging for them to meet the requirements of multiple platforms, which do not yet follow a global or uniform standard. Therefore, a unified national standard or guideline would significantly streamline compliance and reduce costs.

First Secretary of the German Embassy in Dhaka, Jannis Hussain, highlighted two major challenges: data availability and generation, as well as the required digital infrastructure, which has significant cost implications for suppliers.

The event brought together senior government officials, industry leaders, private-sector actors, and development partners to advance national-level dialogue on product traceability, an urgent prerequisite for sustaining Bangladesh’s export competitiveness in the context of evolving EU market regulations and post-LDC graduation challenges.

The policy discussion reinforced these objectives by examining how improved traceability systems can boost export credibility, promote circularity, and ensure compliance with emerging sustainability and due diligence requirements in global markets.

Abdur Rahim Khan, Additional Secretary and Wing Chief of the Export Wing of the MoC, emphasised the importance of due diligence, citing examples from Thailand and Cambodia, and suggested establishing a national project implementation unit (PIU). Joint Secretary of the Planning Wing, Mostofa Jamal Haider, also highlighted how traceability can help Bangladesh negotiate more effectively in a post-LDC landscape.

Public-sector representatives, including BSTI, BCSIR, BPC, ERD, and the Planning Commission, were present, along with representatives from various textile and apparel associations, the leather sector, the fisheries sector, and other stakeholders who spoke on the occasion.

Begum Khaleda Zia, the former prime minister and a towering figure in the nation’s democratic and economic history, died at Evercare Hospital in the capital’s Bashundhara neighbourhood on Tuesday morning, 30 December 2025.

BUILD expresses its profound shock and deepest condolences on her passing.

As the first female prime minister of Bangladesh, Begum Khaleda Zia’s leadership marked a pivotal transition in our nation’s trajectory. Beyond her role in restoring parliamentary democracy, her administration helped steer Bangladesh toward a more market-oriented and outward-looking economy at a time when the country was emerging from prolonged military rule and had limited productive capacity. Her government introduced important reforms, including early support for export‑oriented industries, modernisation of the tax system through the Value Added Tax Act of 1991, and steps to strengthen financial sector regulation. Measures such as current account convertibility further integrated Bangladesh into global markets. These initiatives laid the groundwork for private sector-led growth and created an environment in which entrepreneurship could begin to flourish.

BUILD particularly recognises her visionary focus on rural welfare and job creation. By prioritising the economic empowerment of the grassroots, she helped integrate the rural economy into the national value chain. Her government’s efforts in liberalising trade and encouraging industrialisation provided the early impetus for the vibrant private sector we see today.

Begum Khaleda Zia’s legacy as a pioneer in the Muslim world, and her restrained yet resolute leadership style, have earned her a definitive place in South Asian history. We honour her unwavering commitment to the sovereignty of Bangladesh and her enduring contributions to its socio‑economic fabric.

On behalf of the Board of Trustees and the Secretariat of BUILD, we extend our heartfelt sympathies to her family, associates, and the people of Bangladesh. We pray for the eternal peace of her departed soul.

Following a prolonged business slowdown in 2025, marked by weak investment, sluggish export, high interest rates and persistent inflation, the private sector is looking for a turnaround in 2026. For Bangladesh’s business community, the year 2026 is not about political transitions; it is about whether confidence can return to the economy. Over the past few years, businesses have operated in survival mode. Currency volatility, high borrowing costs, weak demand, energy uncertainty, and regulatory unpredictability have forced many firms to postpone expansion, freeze hiring, or divert capital elsewhere. Even profitable companies have become cautious. The result is visible in the data: low private investment, slow job creation, and subdued growth momentum. The new government inherits this reality. What the private sector now needs is not grand promises, but clarity and credibility.

Investment does not respond first to incentives. It responds to confidence. At present, confidence remains fragile. Policy reversals, inconsistent enforcement, and unresolved weaknesses in the banking sector have made businesses defensive. Domestic investors hesitate to reinvest their retained earnings. Foreign investors compare Bangladesh not to its past performance, but to competing destinations in the region.

The most important signal the new government can send is predictability. Stable rules, transparent decision-making, and respect for contracts matter more than short-term concessions. Without these, no tax break or stimulus package will unlock meaningful private investment.

High interest rates and tight credit conditions have become a major constraint, particularly for small and medium enterprises. Access to finance has narrowed just as operating costs have risen. For many firms, expansion is no longer a question of demand, but of affordability. Businesses understand the
need to control inflation and stabilise the macroeconomic condition. However, prolonged financial stress risks turning stabilisation into stagnation. When credit is scarce or expensive, firms delay investment, productivity suffers, and jobs disappear. What the private sector wants is not artificially cheap money, but a credible roadmap for financial sector reform. Cleaning up non-performing loans, improving governance, and restoring trust in banks would lower risk premiums and revive productive lending.

Predictability is the clearest signal the new government can send. Stable rules, transparent decisions and respect for contracts matter far more than short‑term concessions. Without them, no tax break or stimulus will unlock real private investment.

Unemployment, especially among young and educated workers, is often treated as a social issue. It is also a core business concern. Companies need skilled and motivated employees. They also need consumers with purchasing power. An economy that fails to create jobs weakens both supply and demand. Over time, talent leaves, informality rises, and growth
potential erodes.

Job creation does not require massive new megaprojects. It requires an environment where small and medium enterprises, light manufacturing, logistics, construction, and services can grow. These sectors are labour‑intensive and quick to respond if regulatory bottlenecks are reduced and financing improves.

The expectations are practical but not easy to address. First, both institutional and regulatory reform initiatives, particularly in the financial sectors, must continue and move beyond cosmetic fixes. Transparency, accountability, credible enforcement, and honest communication about constraints and timelines are essential to restore trust and revive productive lending. Second, policy predictability must become a governing principle. Simplified taxation, streamlined licensing, and consistent regulation would do more to unlock investment than any short‑term stimulus. Third, growth must be explicitly linked to employment. Supporting small and medium enterprises, light manufacturing, construction, and services can generate jobs faster than capital‑intensive projects. Fourth, human capital policy must become market‑driven. Education and training systems need closer alignment with labour market demand, particularly for youth and women. Businesses do not expect instant recovery. They expect seriousness.

The new government begins its term under economic strain, but that also creates opportunity. Early, credible signals can restore confidence faster than any stimulus package. Capital is cautious, not absent. It is waiting. If 2026 delivers predictability, discipline, and reform intent, investment will follow and jobs will return. If uncertainty persists, hesitation will deepen.

For the private sector, the message is simple: growth will not come from slogans. It will come from signals.

Ferdaus Ara Begum​
CEO, BUILD

Bangladesh’s private sector continues to navigate an extended period of economic uncertainty, marked by missed opportunities to improve the business climate. The interim government now has a critical opportunity to break this impasse by prioritising key ease-of-doing-business reforms. Simplifying bureaucratic procedures—such as the notoriously cumbersome process for obtaining a trade licence—would be a strong start after years of unfulfilled promises to streamline business registration.

Entrenched overregulation remains a major barrier, often reflecting a deep-seated trust deficit between public regulators and private enterprises. Opening a new business still requires navigating a maze of redundant licences and certificates. For example, while a prospective restaurateur faces nineteen separate approvals (when one robust fire safety clearance might suffice), the high-risk transport sector operates with minimal oversight. A high-level coordinating body—such as the PSDPCC) under the CAO—should be empowered to review and rationalise the regulatory regime to strike the right balance, he added.

Bangladesh’s sluggish pace of reform is thrown into sharp relief by regional peers such as Vietnam. The private sector remains largely unprepared for this transition to a developing country, having been battered by recent global disruptions—from the COVID-19 pandemic to the Ukraine–Russia conflict and domestic political upheavals. Policymakers tout post-LDC prospects such as higher foreign direct investment (FDI), but without clear strategies or target sectors, LDC graduation could become merely a symbolic label change rather than a springboard for real economic transformation.

Addressing the nation’s foremost challenge—unemployment—requires a shift in approach. Embracing idea-based financing (in place of traditional collateral requirements) and introducing targeted support—such as a tax holiday for business founders under the age of 30—would give aspiring innovators a much-needed head start.

Platforms such as BUILD have already proposed several “quick-win” regulatory reforms that could be implemented immediately for tangible impact. Ultimately, restoring mutual trust, simplifying regulations, and unleashing the full potential of the private sector will pave the way for Bangladesh’s economic resilience and growth.

Abul Kasem Khan
Chairperson, BUILD

A pivotal consultation on the draft National Logistics Policy 2025 (NLP 2025) was convened by the Chief Adviser’s Office on 29 September 2025, bringing together key leaders from the private sector, development partners and government institutions. The session, chaired by Md Saifullah Panna, Secretary of the Chief Adviser’s Office, aimed to incorporate critical stakeholder feedback into the finalisation of the policy framework. BUILD played a prominent role in the dialogue, offering strategic recommendations to ensure the policy is both actionable and implementation-ready.

The consultation began with a presentation on the draft policy, which sets out an ambitious vision to transform Bangladesh into a regional trade and logistics hub by 2050. The presentation was followed by extensive discussions among private sector representatives and trade associations, who highlighted persistent challenges, including high port charges, lengthy clearance times, and fragmented digital processes. A strong consensus emerged on the necessity of moving beyond partial digital initiatives to achieve 100 per cent paperless and fully digitalised logistics systems, thereby significantly reducing operational time and costs.

Representing the coordinated voice of the private sector, Abul Kasem Khan, Chairperson of BUILD, delivered substantive recommendations to strengthen the policy’s implementation framework. He emphasised that the success of NLP 2025 will depend on a time-bound action plan and a comprehensive master plan to align the multiple agencies working within the logistics ecosystem. Khan further proposed that the policy should include a clear directive for establishing a dedicated and empowered logistics authority or ministry to ensure coherent, accountable governance across the sector.

Khan also recommended expanding the policy’s scope to incorporate critical infrastructure elements such as inland container terminals (ICTs), global distribution centres and logistics parks within special economic zones (SEZs). Additionally, he called for the inclusion of central chambers and associations, including Bangladesh Garment Manufacturers and Exporters Association (BGMEA), Bangladesh Knitwear Manufacturers and Exporters Association (BKMEA), DCCI, and MCCI, within the National Logistics Development and Coordination Committee (NLDCC) to ensure comprehensive stakeholder representation.

Echoing these priorities, Ferdaus Ara Begum, CEO of BUILD, emphasised the importance of adopting a phased implementation strategy—with short-, medium- and long-term milestones—to steer the policy’s execution through to 2050 effectively. She reiterated the call for an integrated institutional structure, emphasising that an empowered logistics authority is crucial to implementing the complex reforms outlined in the policy.

A high-level meeting was held on 16 September 2025 between representatives of Business Initiative Leading Development (BUILD) and senior officials of the Chief Adviser’s Office (CAO), including M. Siraz Uddin Miah, Principal Secretary to the Chief Adviser; M. Saifullah Panna, Secretary of the CAO; and Dr Ahmed Ullah FCMA, Director General (1), CAO.

The BUILD delegation, led by Abul Kasem Khan, Chairperson of BUILD, included Kamran Tanvirur Rahman, President of the Metropolitan Chamber of Commerce and Industry (MCCI) and Trustee Board Member of BUILD; Ferdaus Ara Begum, CEO of BUILD; Kanis Fatama, Senior Research Associate; and Ahmed Julker Nine, Research Associate. The meeting focused on strengthening coordination for private sector development and advancing the logistics sector in Bangladesh.

Abul Kasem Khan opened the discussion by highlighting BUILD’s significant role in driving private sector reform, noting that 451 out of 1,197 reform proposals submitted by the organisation have already been implemented. He underscored the vital role of the PSDPCC in resolving multi-ministerial policy challenges and proposed the establishment of two new bodies—the National Infrastructure Development and Monitoring Authority (NIDMA) and the National Integrated Logistics Authority (NILA)—both to be overseen by the CAO.

Ferdaus Ara Begum elaborated on the organisation’s pioneering efforts in securing formal recognition for the logistics sector and its 21 sub-sectors in the National Industrial Policy 2024. She highlighted the contributions of the Logistics Infrastructure Development Working Committee (LIDWC), which organised national workshops that ultimately led to the formation of the National Logistics Development Coordination Committee (NLDCC).

The CAO Secretary emphasised the need for in-depth studies to enhance trade competitiveness through a more integrated logistics system. Dr Ahmed Ullah confirmed that the Asian Development Bank (ADB) has committed funds for a logistics sector study, while the World Bank Group has also expressed strong interest in supporting related initiatives.

In his concluding remarks, M. Siraz Uddin Miah acknowledged existing gaps in inter-ministerial coordination and reaffirmed the government’s commitment to addressing them through mechanisms such as the PSDPCC. He also announced the forthcoming launch of the “Nagorik Seba” platform, which aims to digitalise and streamline public service delivery for citizens.

BUILD organised a dialogue titled “Policy reform requirements for non-adjustable TDS” on 17 September 2025 at the DCCI Auditorium, Dhaka. Md Abdur Rahman Khan, Chairman of the National Board of Revenue (NBR), attended as the chief guest, while Dr Mohammad Abu Yusuf, Secretary, Ministry of Social Welfare, was present as a special guest.

The event aimed to recommend practical reforms and present an actionable roadmap to simplify the TDS refund system, thereby enhancing transparency, efficiency, and fairness for taxpayers.

In his address, NBR Chairman Md Abdur Rahman Khan noted that while TDS is an effective global practice, its implementation in Bangladesh has been constrained by operational inefficiencies, resulting in delays in adjustments. He mentioned that the analytical tools within the ASYCUDA system are not being fully utilised. To address these issues, he stated that the NBR is gradually reducing TDS rates and is likely to automate the TDS refund system in the coming months. He further observed that, in some cases, advance income tax (AIT) rates stand as high as 20 per cent—nearly equivalent to the corporate tax rate. He emphasised the need for urgent research to develop benchmarks for rationalising and making TDS rates sector-specific, while ensuring tax justice without compromising the tax-to-GDP ratio.

Dr Mohammad Abu Yusuf, Secretary, Ministry of Social Welfare, highlighted policy gaps and inconsistencies, citing international examples of more efficient tax refund systems. He remarked that delays in receiving refunds block working capital and reduce the profitability of small enterprises. He suggested that integrating the informal economy into the tax system could significantly enhance Bangladesh’s tax-to-GDP ratio.

Taskeen Ahmed, President of the Dhaka Chamber of Commerce and Industry (DCCI), expressed his organisation’s interest in collaborating with BUILD to simplify the TDS process.

Abul Kasem Khan, Chairperson of BUILD, described the current refund system as “very complicated”, noting that some businesses are forced to maintain two separate accounting systems. He attributed the low tax-to-GDP ratio to a cumbersome tax structure and stressed that without mutual confidence between the public and private sectors, no substantial improvement could be achieved.

In the keynote presentation, Dr Wasel Bin Shadat, Research Director at BUILD, explained that the non-adjustable nature of tax deducted at source (TDS) under Section 163 of the Income Tax Act 2023 often acts as a de facto minimum tax. This creates significant liquidity constraints for businesses and contributes to a low share of direct tax revenue—currently around 33 per cent of total NBR revenue. He added that the existing refund process is slow and lacks a digital pathway, leading to substantial delays.

BUILD’s research, presented by Dr Shadat, revealed that policy inconsistency, minimum tax and supplementary duty (SD) have raised the total tax incidence (TTI) in the beverage sector from 42 per cent to 53.95 per cent over the past five years. SD alone doubled from 15 per cent in 2021 to 30 per cent in 2024—the highest rate in the region. The minimum income tax also rose fivefold from 0.6 per cent to 3 per cent in a single year. As a result, the sector’s revenue fell by more than 20 per cent year-on-year due to an increased tax burden.

His presentation outlined a three-phase reform roadmap:

• Immediate Action
  Introduce a board-prescribed refund form (IT-RFD-01) and issue a circular clarifying the distinction between adjustable and final withholdings.
• Medium-Term Goals
  Develop a fully automated TDS e-reporting and e-refund portal, incorporating risk-based verification to process low-risk claims within 30 working days.
• Long-Term Strategy
  Phase out the broad minimum-tax treatment under Section 163 by recalibrating TDS rates based on sector profitability and broadening the tax base to secure stable revenue collection.

Ali Zaman, President of the SME Owners Association, noted that while SMEs previously received TDS refunds by cheque, the current process has become significantly more complex.

Md Hafizur Rahman, former Director General of the WTO Cell, MoC, underscored the importance of tax justice and proposed differentiated tax structures to accommodate the diversity of taxpayers.

Shadab Ahmed Khan, Managing Director of Coca-Cola Bangladesh Beverages, emphasised that although Bangladesh remains an attractive destination for investors, complex tax policies act as a deterrent. He observed that the TTI in the beverage sector has risen from 42 per cent in 2016 to 54 per cent owing to such inconsistencies.

Snehasish Barua FCA, Partner at Snehasish Mahmud and Company, referred to the Finance Ordinance, which indicates the NBR’s intention to gradually reduce TDS rates. He stated that the refund mechanism could be improved through new rules currently awaiting approval, which would minimise non-adjustability. He further noted that growth in tax revenue depends on stronger value added tax (VAT) performance.

Dr Muhammad Abdul Mazid, former Chairman of the NBR, urged both the NBR and taxpayers to act sincerely to raise the tax-to-GDP ratio. He suggested that large business associations allocate at least 2 per cent of their revenue to research.

A. K. M. Badiul Alam, Member (Income Tax Policy) at the NBR, commended the refund workflow proposed by the keynote speaker.

In her closing remarks, Ferdaus Ara Begum, CEO of BUILD, highlighted a key trend: the share of TDS in total income-tax revenue has increased from 84.6 per cent to 87.4 per cent, while TDS refunds have fallen from 0.35 per cent to 0.24 per cent of total TDS collected. She observed that this decline persists despite clear policy provisions for refunding adjustable TDS with 10 per cent interest and direct bank transfers of excess tax payments to beneficiaries.

Other participants in the open discussion included Md Abdul Matin FCMA, Managing Director, Security 360 Limited; Dr A. K. M. Atiqul Haque, Joint Secretary, Ministry of Finance (MoF); Alimul Ahsan Chowdhury, President, Agricultural Machinery Manufacturers’ Association Bangladesh; Shankar Kumar Roy, Executive Director, Bangladesh Cement Manufacturers Association; and M. S. Siddiqui, CEO, Bangla Chemical.