Myanmar Double Taxation Agreements
Written by Interactive Associates. Posted in Accounting
Myanmar has signed an Avoidance of Double Taxation Agreement with the United Kingdom, Singapore, India, Malaysia, Vietnam and South Korea.
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.
In all DTAs, tax on dividends is exempted.
Myanmar Double Taxation Agreements
Written by Interactive Associates. Posted in Accounting
Myanmar has signed an Avoidance of Double Taxation Agreement with the United Kingdom, Singapore, India, Malaysia, Vietnam and South Korea.
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.
In all DTAs, tax on dividends is exempted.
Myanmar Double Taxation Agreements
Written by Interactive Associates. Posted in Accounting
Myanmar has signed an Avoidance of Double Taxation Agreement with the United Kingdom, Singapore, India, Malaysia, Vietnam and South Korea.
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.
In all DTAs, tax on dividends is exempted.
Myanmar Double Taxation Agreements
Written by Interactive Associates. Posted in Accounting
Myanmar has signed an Avoidance of Double Taxation Agreement with the United Kingdom, Singapore, India, Malaysia, Vietnam and South Korea.
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.
In all DTAs, tax on dividends is exempted.
8 Wilkie Road, #03-08 Wilkie Edge Singapore 228095 Tel : 6594 7852 Email : cindylim@rsmchiolim.com.sg Structuring of investment into Myanmar
Do I need an intermediate holding company in
say BVI or a separate company in Singapore to hold the investment in Myanmar in view of potential risks? How would the Singapore company be taxed when it receives foreign-source dividends or interest from Myanmar or should the company retain such income outside of Singapore? How best to maximize the use of DTA provisions in particular with regard to technical or managerial support services rendered from Singapore? 2 Singapore versus Myanmar
Singapore Myanmar
Corporate tax rate 17% 25%
Capital gains tax 0% 10% [Higher rates for Oil & Gas sector] Withholding tax rate - Dividends 0% 0% - Interest 15% 15% - Royalties 10% 20% Has a Double Tax Agreement with N/A Yes Singapore Singapore - Myanmar Double Tax Agreement [“DTA”]
Applicability of DTA provisions Must be tax resident of the
contracting state to claim DTA benefits Tax residency Where the effective management of the company is exercised
Permanent Establishment [“PE”] A PE could include:
a fixed place of business in Myanmar through which the business of a Singapore company is wholly or partly carried on the provision of services by a Singapore entity through its employees based in Myanmar where the activities continue for the same or a connected project for more than 6 months within any 12-month period Reduced tax rates under Singapore-Myanmar DTA Types of income Myanmar DTA Domestic Rate Rate Dividends 0% 0% Interest 15% 10% [Beneficial owner] Royalties 20% Either 10% [Beneficial owner] or 15%
Capital gains on 10% 10%
share sales [if ≥ 35% interest] Service provision by 3.5% 0% if no PE in Singapore entity in Singapore* Myanmar
* A certification process from the Myanmar tax authority is required