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  • Maximise Use of Tax Treaty Provision

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    THAN HAN
    91 просмотров6 страниц
    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.

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    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.

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    Maximise Use of Tax Treaty Provision

    Загружено:

    THAN HAN
    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.

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    из 6

    Maximise the use of

    Singapore-Myanmar Tax Treaty


    Cindy Lim, Tax Partner
    9 July 2012

    RSM Chio Lim LLP


    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


    Thank You

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