Myanmar Double Taxation Agreements
The agreement with the United Kingdom, which is the first DTA agreement Myanmar entered into, was signed on 12-3-1953. There are no specific provisions as regards taxes on interest and technical fees. The country where shipping lines and airlines headquarter takes the tax. Tax on royalties shall be collected at a reasonable rate in the country where the income is earned.
Myanmar and Malaysian reached Avoidance of Double Taxation Agreement on 9-3-1998. The two countries have agreed to collect up to 10 percent tax on interests, royalties and technical fees. The country which has the control of airline collects the tax and 50 percent tax is due to the country which owns the shipping line.
About a year later on 23-2-1999, Myanmar signed another agreement with Singapore. According to the agreement, the tax on interest of financial institutions including banks is up 8 percent and that of others is up to 10 percent. Like other agreements, tax on royalties is set to be up to 10 percent. The agreement copied the provisions of Myanmar-Malaysian contract as regards the shipping line and airlines. The two ASEAN countries made no provisions for technical fees in the agreement.
Ref:http://www.interactivemyanmar.com/accounting/myanmar-double-taxation-agreements/
Ratification Of The Agreement Between Singapore And Myanmar For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income
An Agreement between the Government of the Republic of Singapore and
the Government of the Union of Myanmar for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion with respect to Taxes on
Income was signed in Yangon on 23 February 1999.
2 The Agreement enters into force today following the completion of
ratification formalities. Its provisions shall have effect in Myanmar on
income derived on or after 1 April 2000, and in Singapore on income
assessable for the year of assessment 2002, ie. generally on income
derived on or after 1 January 2001.
3 The main objective of the Agreement is to provide a framework to
facilitate greater cross-flows of trade, investment, technical know-how
and expertise between Singapore and Myanmar thereby strengthening
bilateral economic links for the benefit of both countries.
4 Under the Agreement, the profits derived by an enterprise of one
country from operating aircraft to the other country will be exempted
from tax in that other country. The tax on profits derived from the
operation of ships is reduced by 50%. The rate of withholding tax on
interest will be reduced to 8% of the gross amount if it is received by a
bank or financial institution, and to 10% of the gross amount in other
cases. The rate of withholding tax on royalties will be reduced to 10%
or 15% of the gross amount, depending on the types of royalties
concerned.
5 At present, both countries do not impose tax on dividends in
addition to the tax chargeable on the profits of a company. However, the
Agreement specifies a limit to the tax rate applicable to dividends,
should either or both countries impose such a dividend tax in future.
6 To provide relief from double taxation, Myanmar will allow tax paid
in Singapore as a credit against Myanmar tax on income derived from
Singapore. Similarly, Singapore will allow tax paid in Myanmar as a
credit against Singapore tax on income derived from Myanmar. In the case
of dividends received from Myanmar, the Myanmar tax on that portion of
the profits out of which the dividends are paid will qualify for tax
credit in Singapore if the shareholder is a company which is a resident
of Singapore and which owns directly or indirectly at least 10% of the
share capital of the dividend-paying company. Both countries also agreed
to allow tax sparing credit to their residents. That is to say, where
income tax has been relieved or reduced in one country by virtue of its
tax incentives, the tax so relieved or reduced will be treated as if it
has been paid and will therefore be allowed as a credit in the other
country.
7 The full text of the Agreement is published in the Government
Gazette today. With the coming into force of this Agreement, Singapore
now has in force comprehensive Agreements with 40 countries. Further
enquiries on the Agreement may be referred to Mr Tang Yam Soon of the
Inland Revenue Authority of Singapore at Tel No. 3512119.
Maximise Use of Tax Treaty Provision by Than Han on Scribd
Singapore-Myanmar DTA (26 June 2009) by Than Han on Scribd
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