Myanmar is now a popular destination for manufacturers to outsource due to low production costs especially due to the change in political climate to favour a more democratic regime thus promoting economic growth in the process. Before sanctions were imposed upon Myanmar, 85% of its export market had been through the manufacturing of apparel. The reason why Myanmar was and is, a target for manufacturing is mainly due to the labour force that can be attained at low costs. Whereas, China, Myanmar’s biggest manufacturing rival has faced an increase in labour wages. Myanmar’s automotive market and car penetration ratio (per population) have been growing rapidly, but mostly by imported second hand cars. However, within the last few years, import restrictions have relaxed thus attracting a diverse range of car manufacturers including Suzuki, Chevrolet and Toyota amongst many others. Although these restrictions have relaxed, companies such as Toyota have preferred to manufacture within the country as products that are manufactured within the country are exempt from the taxes imposed which are still deemed to be relatively high. The establishment of the Thilawa Special Economic Zone (“SEZ”) has also provided favourable conditions for manufacturers. A joint venture between Japan and Myanmar, the Thilawa SEZ provides infrastructure as well as economic benefits such as exemption from corporate tax after registration and has therefore been a manufacturing haunt for various companies. The range of investors in Thilawa SEZ are not only multi-national but also expands over a variety of sectors from service to manufacturing. Manufacturing, makes up the bulk of the portion. Investors in the manufacturing sector includes Millcon Thiha Gel Ltd (manufacture of steel products), Marketech Integrated Manufacturing Co., Ltd (Manufacture of automated and 1 This memorandum is for informational purposes only and is not to be taken as legal advice. Should you require legal assistance on any matter discussed in this memorandum, please contact us separately for a specific engagement. Kelvin Chia Yangon Ltd (KCY) Level 8A, Union Financial Center, Corner of Mahabandoola Road and Thein Phyu Road, Botahtaung Township, Yangon. (951)8610348/8610349 [email protected] www.kcpartnership.com LEGAL PARTNERS ACROSS ASIA customised production lines) and Suzuki Thilawa Motor Co., Ltd (manufacture of automobiles). 1.1. Government Automotive Policy Myanmar government has set out the Automotive Policy in 2019 to increase the usage of motor vehicles with affordable price in each and every sector and for the acceleration of Unit in Operation (UIO). In the policy the government set out the short-term, medium-term, and long-term targets for the increase of UIO together with the brand-new car sales per year as follows: Step Target Period Vehicle Penetration Ratio UIO (unit) Brand-new Car Sales / year (unit) (a) Short-term (initial stage 5 years) 4% 2,000,000 200,000 (b) Medium-term (second stage 5 years) 8% 4,000,000 400,000 (c) Long-term (third stage 5 years) 20% 10,000,000 1,200,000 The initial stage aims at encouraging Semi Knocked Down system (SKD) and step-bystep reduction and slowly eradication of used-car imports. In order to encourage local assembly of new cars, the government plans to allow foreign investments as Joint-Venture or 100% FDI in accordance with the market demand. Another objective of the policy is to gradually decrease the right-hand drive cars which currently dominate the market due to import of Japanese used-cars and replace them with left-hand drive cars, preferably manufactured locally. Traditionally, Myanmar car market consisted of imported cars – primarily secondhand cars from Japan. Since the government introduced regulations to only allow imports of left-hand drive vehicles in 2018, it has become more difficult and expensive to import vehicles, leading the buyers to locally assembled SKD vehicle market. 2. MYANMAR’S GENERAL INVESTMENT FRAMEWORK Myanmar’s investment framework is currently generally governed by the Myanmar Companies Law (2017) (“MCL”),2 the Myanmar Investment Law (2016) (“MIL”)3 and the Special Economic Zone Law (2014) (the “SEZ Law”).4 Specific investment activities are also subjected to special laws, regulations, and/or relevant government policies. 2 Pyidaungsu Hluttaw Law No. 29/2017, 3rd Waning of Nadaw 1379 ME. 3 Pyidaungsu Hluttaw Law No. 40/2016, 2nd Waning of Thandingyut 1378 ME. 4 Pyidaungsu Hluttaw Law No. 1/2014, 8th Waning of Pyatho 1375 ME. LEGAL PARTNERS ACROSS ASIA 2.1. Foreign Investment Activities under the Myanmar Companies Law In order to conduct business activities in Myanmar, a foreign investor must establish either a branch office or private limited company under the Companies Act with the Directorate of Investment and Company Administration (“DICA”) of the Ministry of Planning and Finance. There is no separate concept of a representative office in Myanmar, and therefore foreign companies that wish to establish a representative office typically register as an Oversea Corporation. A private limited company established by foreigners in Myanmar can be wholly foreign-owned or registered as a joint venture company with Myanmar nationals. Previously, foreign ownership of even one share made a company foreign but the MCL provides a different definition of a foreign company as “a company incorporated in Myanmar in which an overseas corporation or other foreign person (or combination of them) owns or controls, directly or indirectly, an ownership interest of more than thirty-five percent.” Thus, companies with foreign investors are not automatically considered as foreign companies provided that their ownership in the company does not exceed 35%. However, redefining a foreign company did not result in foreigners being automatically allowed to invest in a particular sector in Myanmar up to the prescribed ownership amount. Whether or not foreigners will be permitted to invest in a particular sector in Myanmar still further depend on laws and policies or sought to be implemented for each specific sector, and the intended activity in relation to foreign investment. Note that while the MCL allows foreigners to register overseas corporations and establish private limited companies in Myanmar, investors intending to engage in specific sectors (such as manufacturing) or secure additional concessions from the Myanmar government (such as under the provisions of the MIL or the SEZ Law) must register as a private limited company in order to apply for such additional concessions. 2.2. Foreign Investment Activities under the MIL The MIL was enacted on 18 October 2016 to govern investments by both Myanmar and foreign investors. The MIL expressly repealed the Myanmar Foreign Investment Law (2012)5 and the Myanmar Citizen’s Investment Law (2013)6 . The MIL establishes conditions and regulations with respect to investments in Myanmar as well as the guarantees and benefits afforded to investors. 5 Pyidaungsu Hluttaw Law No. 21/2012, 3rd Waning of Thandingyut 1374 ME (2 November 2012). 6 Pyidaungsu Hluttaw Law No. 18/2013, 7th Waning of Waso 1375 ME (29 July 2013). LEGAL PARTNERS ACROSS ASIA 2.2.1. Investments Under the MIL Under the investment framework of the MIL and as supplemented by the provisions of the Myanmar Investment Rules (the “MIL Rules”),7 investments and/or business activities are categorized as follows: Type of Investment MIL Rules A. Investments which require a permit from the Myanmar Investment Commission (“MIC Level Investments”)8 1. Strategic for Myanmar Includes those made: a. in the technology, transport infrastructure, energy infrastructure, building urban development infrastructure and new cities, extractive/natural resources or media sectors and has an expected investment value exceeding US$20 million; b. pursuant to the grant of a concession, agreement or similar authorization by an authority and has an expected value exceeding US$20 million; c. in a border region or conflict affected area by foreign investors or in case of Myanmar citizen investors, has an expected investment value exceeding US$1 million; d. and conducted across the national border by foreign investors or in case of Myanmar citizen investors and has an expected investment value exceeding US$1 million; e. and conducted across the States or Regions; f. primarily for agriculture related purposes and includes rights to occupy or use more than 1,000 acres of land; or g. primarily for non-agricultural related purposes and includes rights to occupy or use more than 100 acres of land. 7 MIC Notification No. 25/2017 (30 March 2017). 8 MIL (2016), § 36. LEGAL PARTNERS ACROSS ASIA Type of Investment MIL Rules 2. Capital intensive ventures An investment is taken to be a large capital intensive venture or investment if the expected investment value exceeds US$100 million. 3. Projects which have the potential to negatively impact the environment or local communities a. It has been or is likely to be classified as an EIA-type project; b. The investment is located under a designated protected or reserved area or major biodiversity area under the laws in force including the Environmental Conservation Law (2012)9 (“ECL”) or areas selected and specified to support the ecosystem and cultural and natural heritage, cultural commemoration and unspoilt areas; or c. It includes rights to occupy or use land which: (1) has been or is likely to be acquired through expropriation, compulsory acquisition procedure or by agreement in advance of such expropriation or compulsory acquisition procedure in accordance with the laws of Myanmar and will either cause the relocation of at least 100 individuals permanently residing on such land or comprise an area of more than 100 acres; (2) comprises an area of more than 100 acres and would be likely to cause involuntary restrictions on land use and access to natural resources to any person having a legal right to such land use or access; (3) comprises an area of more than 100 acres and which is the subject of a pre-existing bona fide claim or dispute by a person regarding rights to occupy or use such land in a way which would conflict with the 9 Pyidaungsu Hluttaw Law No. 9/2012, 8th Waxing Day of Tagu 1373 ME (30 March 2012). LEGAL PARTNERS ACROSS ASIA Type of Investment MIL Rules proposed investment; or (4) would otherwise adversely impact the legal right of at least 100 individuals occupying such land to continue to occupy such land. 4. Business activities that will use state-owned land and buildings An investment is taken to use state-owned land and buildings if a government authority has the land, building or relevant land rights and is authorized to transfer or deal in such land, building or rights in the capacity of an owner or occupier. It does not include land use rights arising from the grant, alteration or other administration of land rights pursuant to a statutory land administration process within the responsibility of the government authority. 5. Business activities that are designated by the government to require the submission of a proposal to the commission B. Prohibited Investments10 1. Investment activities which may bring or cause hazardous or poisonous wastes into Myanmar The MIC is authorized to issue notifications setting out the list of prohibited investment activities, such list has not yet been issued. The MIC is authorized to request information, order suspension or cessation or revoke the permit or endorsement if it finds that prohibited investment activities are being carried on. 2. Investment activities which may bring technologies, medicines, flora and fauna and instruments which are still being tested abroad or which have not obtained approvals for use, planting and cultivation except the investments which are made for the purpose of research 10 MIL (2016), § 41. LEGAL PARTNERS ACROSS ASIA Type of Investment MIL Rules and development 3. Investment activities which may affect the traditional culture and customs of the racial groups within Myanmar 4. Investment activities which may affect the public health 5. Investment activities which may cause significant damage to the natural environment and ecosystem 6. Investment activities that manufacture goods or provide services that are prohibited in accordance with applicable laws C. Restricted investments11 1. Investment activities allowed to carry out by the government only Automobile manufacturing is not restricted under notification 15/2017 which means the investment may be undertaken as a 100% wholly owned foreign investment. Unless required to secure an MIC Permit (as discussed above), the investor may separately apply for MIC Endorsement under the MIL to enjoy tax incentives and enter into a long term land lease of land (usually for a term of 5 years or more). 2. Investment activities restricted to foreign investors 3. Investment activities allowed only in form of joint venture with a citizen owned entity or a citizen of Myanmar 4. Investment activities permitted with the 11 MIL (2016), § 42. LEGAL PARTNERS ACROSS ASIA Type of Investment MIL Rules recommendation of the relevant ministries of the government D. Others Subject to any other restriction imposed by other applicable laws, investment activities which do not fall under any of the foregoing categories will not be considered as requiring an MIC Permit, prohibited, or otherwise restricted. We note, however that Section 46 of the MIL further empowers the MIC to require the approval of the Union Parliament with respect to specific investment activities which may have a significant impact on security, economic condition, the environment, and national interest of the Union and its citizens. 2.2.2. Benefits In addition to the investment protections granted to investors and investments in Myanmar, MIC Permit holders (those who undertake investment activities covered by MIC Level Investments and are required to obtain an MIC Permit) and other qualified investors may apply for additional benefits and exemptions provided under the MIL. Investors required to obtain an MIC Permit can concurrently apply for such benefits and exemptions which are granted by the MIC as part of the MIC Permit while investors who are not required to apply for an MIC Permit because their investments are not MIC Level Investments, can apply for such benefits and exemptions by seeking an endorsement from the MIC ((“MIC Endorsements”). We discuss briefly below the additional benefits and exemptions below that the MIC is authorized to grant as part of the MIC Permit or as an MIC Endorsement. (a) Land Rights Authorization – Chapter 12 of the MIL expressly provides for a “Land Rights Authorization” whereby holders of an MIC Permit or MIC Endorsement have the opportunity to lease and develop land or buildings on a long term basis, which according to the MIL is a period not exceeding 50 years (renewable for two terms of 10 years each). The MIC may, with the approval of the Union Parliament, grant a longer period to investors who invest in less developed and remote regions.12 12 MIL (2016), § 50(f). LEGAL PARTNERS ACROSS ASIA (b) Tax Incentives – Section 74 of the MIL provides that the MIC shall evaluate and is authorized to grant one or more tax exemptions or reliefs (“Tax Incentives”) if the investor applies for such exemptions or reliefs and satisfies the criteria to be eligible for such exemptions or reliefs as provided by the MIL and the MIL Rules. Such Tax Incentives that may be applied for are as follows: Limited-period income tax exemption – This refers to exemption from income tax for a designated number of years (3, 5, or 7 years) from the commencement of commercial operations depending on the zone (based on level of development of zone) under which the business will be conducted. Exemptions and reliefs from customs duties and other internal taxes - The MIC is authorized to grant exemptions and reliefs to qualified investors on customs duties and other internal taxes on, among others, machinery, equipment, materials not available locally during the construction/preparatory period of the investment.13 Other exemptions and reliefs - The MIC is authorized to grant other exemptions and reliefs to qualified investors such as exemption or relief from income tax if the profit obtained from the investment business that has secured an MIC Permit or MIC Endorsement is reinvested in such investment business or in any similar type of investment business within one year,14 right to deduct depreciation for the purpose of income tax assessment, after computing such depreciation from the year of commencement of commercial operation based on a depreciation rate which is less than the stipulated lifetime of the machinery, equipment, building or capital assets used in the investment,15 and right to deduct expenses from assessable income, incurred for research and development relating to the investment activities/business which is actually required for the economic development of the Union and carried out within the Union.16 Please note that the application for an MIC Permit or MIC Endorsement involves an evaluation of the investment proposal or application, and the MIC Permit or MIC Endorsement is only granted by the MIC in the exercise of its discretion under the MIL and the MIL Rules, after taking into consideration various mandatory as well as non-mandatory factors set out in such said laws. 13 MIL (2016), § 77(a). 14 MIL (2016), § 78(a). 15 MIL (2016), § 78(b). 16 MIL (2016), § 78(c). LEGAL PARTNERS ACROSS ASIA 3. FRAMEWORK OF REGULATION FOR AUTOMOBILE MANUFACTURING 3.1. Private Industrial Enterprise Law (1990) The Private Industrial Enterprise Law (1990) (the “PIEL”) governs all industrial enterprises in Myanmar. Any person desirous of conducting any private industrial enterprise by using any type of power which is three horsepower and above, or manpower of ten wage-earning workers and above, shall register under the PIEL. “Private Industrial Enterprise” is defined as conduct of an industrial enterprise either individually or in partnership, or by forming a company although the express does not include industrial enterprise undertaken in joint venture with the government. The nature of PIEL is intended to cover a broad range of industrial activities including various manufacturing businesses. As such, the law does not provide for specific sector related provisions but sets out a general regulatory authority to oversee industrial enterprises. The regulatory authority is named as the Directorate of Industrial Supervision and Inspection (“DISI”) under the Ministry of Industry. Under PIEL, DISI is responsible for the registration of private industrial enterprises and for issuing various industry guidelines and minimum safety requirements. In addition, DISI has also conferred authority to actively inspect the enterprise in order to make sure the industrial activities are being conducted in accordance with the guidelines and requirements. Under PIEL, industrial enterprises are categorized as small, medium, and large. There are four criteria for being categorized as small, medium, and large: Employment, Power, Capital, or Production Vale. Size Employment (number) Power (H.P) Capital (Myanmar Kyat) Production Value (Myanmar Kyat) Small Up to 50 Up to 25 Up to 1 million Up to 2.5 million Medium 50-100 25-50 1-5 million 2.5-10 million Large More than 100 More than 50 More than 5 million More than 10 million 3.2. Semi Knock-Down Manufacturing Due to limited availability of technology and resources, many automobile manufacturers in Myanmar choose to establish a local assembly plant and undergo a semi knock-down (“SKD”) system of manufacturing, a process where the investor imports various parts of the automobile and then assemble locally. SKD system enjoys the added benefit of substantially lower import duties compared to importing LEGAL PARTNERS ACROSS ASIA ready-to-use automobiles and preferential treatment of motor vehicle registration for locally assembled automobiles. The Myanmar Investment Commission has issued Notification 85/2017 in which the components of the SKD system are prescribed as follows: No. Name of group of component parts 1. Engine assembly, transmission and clutch system 2. Welded/painted body, including chassis group (without installation of combination meters, interior trimming parts, lamps, wind shield and wire harness) 3. Front axles/ front independent suspension/ rear axles 4. Suspension component 5. Steering wheel and related parts 6. Exhaust system 7. Wheels and tires 8. Seat assembly 9. Trimming parts, dashboard, instrument panel, windshields, wire harness and other accessories 10. Door group (front and rear) without accessories 3.3. Regulatory Framework Since automobile manufacturing is a frontier market in Myanmar, there is no overarching regulatory framework for the automobile manufacturing business as a whole. As a result, automobile manufacturing can be understood in terms of a chain of activities where various government authorities have regulatory authority in each of the process. Thus, the entire regulatory framework for automobile manufacturing can be understood as follows: Establishment of entity Directorate of Investment and Company Administration Investment approval (if mandatory, i.e., MIC Permit, or upon investor’s option, i.e., MIC Endorsement) Myanmar Investment Commission Land Use Rights Regional/State Government with Myanmar Investment Commission LEGAL PARTNERS ACROSS ASIA Tax Benefits Myanmar Investment Commission Industrial Enterprise Registration Directorate of Industry Supervision and Inspection Employment of Workers Ministry of Labour, Immigration and Population Import of Materials/Parts Ministry of Commerce Retail/Wholesale (for distribution/ showroom) Ministry of Commerce Motor Vehicle Registration Road Transport Administration Department Additionally, respective regional/state government or zone committee may have their own licensing requirement. For example, in the Yangon Region, a business licence is required for the operation of an industrial plant while in certain industrial zones may have additional zone permits in order to conduct business. 4.3.1. Directorate of Investment and Company Administration Directorate of Investment and Company Administration (“DICA”) oversees the company registration in accordance with the Myanmar Companies Law 2017 (“MCL”). Recently, DICA has revamped the registration process in online registry system called MyCO, and as a result, the investors can establish and register their company easily. DICA also administers other corporate secretarial requirements under MCL through MyCO. 4.3.2. Myanmar Investment Commission MIC is composed of representatives from various ministries in Myanmar and therefore the investment application to MIC is scrutinized in MIC meeting where regulatory authorities from various industries and sectors decide whether the proposed investment is beneficial to the country. MIC issues two types of investment approvals under the MIL, namely, an MIC Permit and an MIC Endorsement. An MIC Permit is required for certain investments as discussed in paragraph 2.2.1; while an MIC Endorsement may be applied for if an investor wishes to enjoy tax benefits or enter into long-term leases of land (usually for a term of more than 5 years). 4.3.3. Regional/State Governments Transfer of Immovable Property Restriction Law promulgated in 1987 prohibits foreigners and foreign companies from owning or leasing land for more than a year. LEGAL PARTNERS ACROSS ASIA However, foreign companies with MIC Permit or Endorsement from MIC are allowed under MIL to enjoy long term land lease in order to conduct investment activities. There are many types of land use rights and private ownership titles in Myanmar. However, land administration is ultimately under respective regional/state government and land management bodies formed by the Union government. 4.3.4. Industrial Enterprise Registration As discussed above, industrial enterprises engaged in manufacturing are required to register with DISI under the Ministry of Industry in accordance with the Private Industrial Enterprises Law (1990). 4.3.5. Employment of Workers Myanmar does not have one solidified law employment and labour matters but many different laws govern different aspects of employment such as Payment of Wages, Minimum Wage Law, Leaves and Holiday Act, and Shops and Establishment Law. Department of Labour under Ministry of Labour, Immigration and Population is mainly responsible for the country’s labour welfare and the regulatory authority concerning labour laws. In addition, Factories and General Labour Laws Inspection Department oversees the labour law compliance of businesses and provide assistance to settlement of labour disputes. 4.3.4. Import of Materials/Parts Import of goods, materials, equipment and parts require import licences from the Ministry of Commerce. As discussed above, the MIC is authorized to grant exemptions and reliefs to qualified investors on customs duties and other internal taxes on, among others, machinery, equipment, materials not available locally during the construction/preparatory period of the investment. 4.3.5. Retail/Wholesale of Automobile Recently, the government liberalized the trading sector in order to promote foreign investments. Foreign investors may now engage in trading activities for certain enumerated goods in accordance with MOC Notification 25/2018. Notably, the sale of automobiles manufactured in Myanmar is not among those for which a trading license may be secured, although such license may not be necessary considering the fact of such on-shore manufacture. Instead, a separate MOC Notification 27/2019 provides for the licensing regime for the operation of an automobile showroom in Myanmar (that is, an importer and/or distributor). The requirements include, among other things, minimum space requirements, a deposit requirement, and provision of after sale services. The requirements concerning automobile showrooms are updated LEGAL PARTNERS ACROSS ASIA annually based on changes in government policy concerning automobiles in Myanmar. 4.3.6. Motor Vehicle Registration All automobiles shall be registered with Road Transport Administration Department (“RTAD”) before they obtain the licence plate to drive on road. Even though there is no official quota of automobiles that can be registered each year, RTAD controls the number of automobiles in each region and state via their internal policy. The current policy is that Yangon region RTAD does not allow new vehicles to register and obtain the licence plate. However, locally assembled automobiles under SKD system may be registered so that it the policy encourages growth of local assembly plants. 4. INVESTMENT APPLICATION PROCEDURE FOR AUTOMOBILE MANUFACTURING 4.1. Establishment of the on-shore operating entity We set forth below the general requirements and procedure for the establishment of the on-shore operating entity. 4.1.1. Company Registration with the DICA As discussed above, the primary step for establishing an on-shore operating entity is the registration of a private limited company with the DICA. The general requirements and procedure are as follows: (a) Create a MyCO account; (b) Collect the required information to register a company. The information typically includes: company name, company contact details, directors and secretary, share capital structure and members, and company constitution; (c) Complete an online application; (d) Receive a Certificate of Incorporation. 4.1.2. Investment Permit Automobile manufacturing enterprise may require an MIC Permit under the MIL framework, depending on the project details and description as discussed above. Alternatively, the investor may seek an MIC Endorsement (as a discretionary matter) should it wish to operate under certain tax concessions, or should its on-shore business require the long-term lease of land. LEGAL PARTNERS ACROSS ASIA 4.1.3. Environmental Impact Assessment All projects and project expansions undertaken by any ministry, government department, corporation, board, development committee and organization, local government or authority, company, cooperative, institution, enterprise, firm, partnership, or individual having the potential to cause adverse impacts,17 are required to undertake Initial Environmental Examination (“IEE”) or Environmental Impact Assessment (“EIA”) or to develop an Environmental Management Plan (“EMP”) and to obtain an Environmental Compliance Certificate (“ECC”). Projects which require an IEE or EIA, an ECC should first have been duly issued before any permit is granted or issued by the relevant ministry, or any other competent authority in respect of any application to proceed with the implementation of such project. 4.2. Post-registration Permits and Licences In addition to the registration requirements listed above, investors will also to have to secure the necessary post-registration permits, which include the usual permits for doing business in Myanmar (e.g., construction permits; approvals, permits and licences relating to constructed buildings and structures, equipment and facilities, and/or the procurement or use of utilities and other essential services; import registrations and licences; tax registrations; labour and employment related registration requirements, etc.). Disclaimer: This information provided by Kelvin Chia Yangon (KCY) in this document is not intended to be received as legal or professional advice, and is for informational purpose only. Should you require specific assistance, please separately consult us. In all cases, any legal advice provided by KCY in the course of any professional engagement is provided in consultation with our own Myanmar qualified attorneys. 17 “Adverse Impact” is defined under the EIA Procedure as “any adverse environmental, social, socio-economic, health, cultural, occupational safety or health, and community health and safety effect suffered or borne by any entity, natural person, ecosystem, or natural resource, including, but not limited to, the environment, flora and fauna, where such effect is attributable in any degree or extent to, or arises in any manner from, any action or omission on the part of the Project Proponent, or from the design, development, construction, implementation, maintenance, operation or decommissioning of the Project or any activities related thereto.” LEGAL PARTNERS ACROSS ASIA Our Partners in Yangon About Kelvin Chia Yangon (KCY) KCY has been in active operation in Myanmar since 1995, currently with offices in Yangon and Mandalay. KCY is the firm of choice for those seeking to navigate Myanmar’s fast-changing and complex regulatory landscape, a jurisdiction in which KCY has gained in-depth legal expertise from the numerous transactions it has handled. Our main practice areas Foreign Investments | Incorporation and Company Maintenance | General Corporate and Commercial | Due Diligence | Mergers and Acquisitions | Joint Ventures and Production Sharing Agreements | Investment Funds | Energy/Oil and Gas | Natural Resources/Mining | Banking | Project and Project Financing | Manufacturing | Education | Agriculture | Real Estate | Infrastructure | Construction | Telecommunications | Compliance / Regulatory | Licensing and Permits | Labour and Employment | Immigration | Taxation | Insurance | International Arbitration | Intellectual Property | Special Economic Zones Yangon Office: Level 8A, Union Financial Center (UFC), Corner of Mahabandoola Road and Thein Phyu Road, Botahtaung Township, Yangon. Mandalay Office: Room No. A-3 (2nd Floor) | Win Yin Mon Condo | 67th Street (31st x 32nd Street) | Chan Mya Thar Zan Township | Mandalay.