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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Burma: Double taxation agreement, Article 16: Non discrimination

(1) The nationals of one of the Contracting Governments shall not be subjected in the territory of the other Contracting Government to any taxation or any requirement connected therewith which is other, higher or more burdensome than the taxation and connected requirements to which the nationals of the latter Contracting Government are or may be subjected.

(2) The enterprises of one of the territories shall not be subjected in the other territory, in respect of profits attributable to their permanent establishments in that other territory. to any taxation which is other, higher or more burdensome than the taxation to which the enterprises of that other territory are or may be subjected in respect of the like profits.

(3) Nothing in paragraph (1) or paragraph (2) of this Article shall be construed as obliging one of the Contracting Governments to grant to nationals of the other Contracting Government who are not resident in the territory of the former Government the same personal allowances, reliefs and reductions for tax purposes as are granted to its own nationals.

(4) In this Article the term `nationals` means -

  1. in relation to Burma, persons who are under the law of the Union of Burma citizens thereof;
  2. in relation to the United Kingdom, all British subjects and British protected persons residing in or belonging to the United Kingdom or any territory to which the present Agreement applies by reason of extension made by the United Kingdom under Article XVII;

and includes all legal persons, partnerships and associations deriving their status as such from the law in force in any territory of the Contracting Governments to which the present Agreement applies.