Explanatory note

Under the Agreement with Burma which is scheduled to this Order, certain classes of income derived from one country by a resident of the other country are (subject to certain conditions) exempt from tax in the former country; these classes are shipping and air transport profits, certain trading profits not arising through a “permanent establishment”, patent and copy-right royalties, pensions, purchased annuities, and earnings of temporary business visitors. Government salaries and pensions are normally taxed by the paying Government only. Remuneration of visiting professors and teachers is exempt in the country visited.

Dividends are exempt from any tax which is additional to the tax charged on the profits represented by the dividend.

Where income continues to be taxable in both countries, credit is to be given by the country of the taxpayer's residence for the tax payable on that income in the country of origin of the income.

Provision is included for the exchange of information between the taxation authorities of the two countries.

The business profits tax imposed by Burma was not covered by the Agreement in the first instance and the Supplementary Protocol has been concluded to extend the Agreement to that tax.

The Agreement (as extended by the Supplementary Protocol) is to take effect for the fiscal year 1948-49.