The Internal Revenue Department (IRD) of Myanmar has issued new regulations on transfer pricing documentation, aligning national requirements with the OECD BEPS framework. The rules, effective from 2026/07/24, require multinational enterprises to prepare and retain master files, local files, and country-by-country reports that detail intra-group transactions, pricing methodologies, and economic justification. Taxpayers must submit these documents to the IRD upon request, and failure to comply may result in penalties of up to 5 % of the disputed tax amount. The guidance also introduces mandatory electronic submission through the IRD’s online portal, reducing processing times. This amendment aims to enhance transparency, curb profit shifting, and bring Myanmar’s tax administration in line with international best practice. The IRD emphasizes that all related‑party transactions exceeding the MMK 50 million threshold must be disclosed in the country‑by‑country report. Affected businesses should review intercompany agreements, document transfer pricing policies, and adjust pricing strategies to reflect arm’s length principles. Companies are advised to conduct internal trainings, update their tax risk frameworks, and begin gathering the requisite documentation well before the effective date to avoid last‑minute compliance gaps. Stakeholders are encouraged to act promptly to align their documentation practices with the new requirements. This proactive approach will also support overall tax compliance and operational efficiency.
Key Takeaways
- Effective Date: 2026/07/24
- Documentation Requirements: Master file, local file, and country-by-country report
- Compliance Impact: Potential penalties for non-disclosure and mandatory electronic filing
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