Myanmar: local rules

Myanmar has no transfer pricing law, no related party definition for tax and no transfer pricing regulations. The brief said the Internal Revenue Department (IRD) had announced transfer pricing rules, but no such rules or notices were found, and PwC's Myanmar summary, last reviewed 9 September 2026, says there are currently no transfer pricing rules. Only general rules exist. Section 32 of the Tax Administration Law (Law No. 20 of 2019, in force 1 October 2019) lets the Director General disregard artificial or fictitious transactions and treat a mischaracterised deal by its economic substance. IRD Public Ruling 3/2022 (16 November 2022, in force 1 January 2023) lists as tax avoidance a failure to value a right, asset, service or benefit at the market price, non-arm's length transfers in cross-border transfer pricing, and splitting income between a taxpayer and associated enterprises to cut total tax. The ruling binds the IRD but not taxpayers (s. 11), and law firms note that no domestic rules back these examples, so how they work in practice is unclear.

There is no transfer pricing file, master file, local file or related party return in Myanmar. The general record rules still apply. A taxpayer must keep accounts, records and the source documents behind them for 7 years, or longer if the assessment time limit is longer, and must give a Myanmar or English translation on request (Tax Administration Law s. 20). The IRD can ask for returns, information and documents (ss. 22 and 73). In practice, auditors expect contracts, invoices and support for related party prices to be on hand. A group that wants protection can prepare an OECD style study for its own use, but the IRD does not require one.

No transfer pricing method is prescribed. The IRD uses market prices of similar deals between independent parties as a guide, with reasoning close to the OECD methods, according to commentary from 2013 that has not been replaced by any rule. Payments to affiliates for royalties, management fees and interest are deductible only if they are in line with the volume of business (PwC summary). The Tax Administration Law s. 12 lets a taxpayer ask the Director General for a binding advance ruling on a proposed deal. No transfer pricing advance pricing agreement programme was found.

No transfer pricing penalty exists. Penalties come from the Tax Administration Law. A late return costs the greater of 5% of the tax owing plus 1% for each month or part month, or MMK 100,000 (s. 67). An understatement from intentional conduct or negligence costs 25% of the underpayment, or 75% if it is over MMK 100 million or 50% of the person's tax (s. 68), and a false or misleading statement costs MMK 150,000 plus the tax difference (s. 69). Failing to keep documents costs MMK 5,000 to 100,000 a day by tax size (s. 70), failing to answer an information notice up to MMK 500,000 (s. 73), and late payment 10% of the unpaid tax (s. 74). Wilful evasion is a crime with a fine and up to 7 years in prison (s. 77), the assessment time limit is 6 years (12 for fraud or wilful neglect, s. 29), and the Director General can waive a penalty for reasonable cause (s. 64(i)).

Myanmar has not adopted Pillar Two. No income inclusion rule, undertaxed profits rule or domestic minimum top-up tax was found in the Union Tax Laws, and PwC's summary reports no significant corporate tax developments in the past year. Myanmar is not on the OECD list of Inclusive Framework members (updated 5 December 2025). A Myanmar subsidiary of a large group can still be affected by the Pillar Two rules of its parent's country.

Myanmar has no country-by-country reporting rule, no CbC notification and no master file. It is not on the CbC multilateral competent authority agreement signatory list (updated 29 July 2026). The tax year is fixed at 1 April to 31 March for all companies, the annual return is due 3 months after year end (30 June), and income tax is also paid in quarterly instalments within 10 days after each quarter end. A due date that falls on a day the IRD is closed is met if the act is done on the next day it is open (Tax Administration Law s. 19(a)), so the tool moves weekend and public holiday dates to the next working day. The Union Tax Law 2026 (Law No. 18/2026, enacted 15 March 2026, in force 1 April 2026) kept the 22% company rate, with 17% for companies listed on the Yangon Stock Exchange and 25% for oil and gas exploration and production. International sanctions may restrict dealings with some Myanmar entities and individuals, so users should check the sanctions rules that apply to them.