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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Burma: Dividends

The agreement has not been amended, so that

  1. the ‘statutory income’ basis (see INTM161140 onwards) is available to the taxpayer regardless of the date on which the income arises.
  2. where the dividend is an ordinary dividend, or the participating part of a participating dividend, credit is available for the Burma underlying tax (see INTM164010(d), whether the shareholder receiving the dividend is an individual or a company and regardless of the recipient’s shareholding in the paying company (see INTM164410 for guidance on the determination of the rate of underlying tax).