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Mauritius: Double Tax Treaties

Introduction

This page was last updated on 2 April 2021.

Unusually for a low-tax jurisdiction, Mauritius has entered into a considerable number of double-tax treaties. Generally speaking, the treaty benefits are available to all Mauritian companies other than ‘international’ ones.
All Mauritian treaties are based on the OECD model treaty and contain exchange of information clauses. However, the exchange is limited to matters concerning the working of the treaties themselves.
The treaty with India, which had underpinned the emergence of Mauritius as the dominant channel for foreign direct investment in India, came under attack from Indian tax authorities in 2002 due to alleged abuses by Indian-resident investors.
In October 2006, the Mauritian government announced that it would tighten up rules on how tax residence certificates are issued; in future it would issue them for only one year at a time. Various other restrictions were imposed at this time, including on the issue of category 1 global business licence applications
Finally, in May 2016, a protocol for the Indo-Mauritian tax treaty was produced. From 1 April 2017, the start of financial year 2017-2018, capital gains arising from shares of India-resident companies were no longer exempted from tax. However, until 31 March 2019, capital gains tax will be levied at 50% of the domestic Indian tax rate.

The DTAA with Indonesia, for somewhat similar reasons, was cancelled on 1st January 2005 after the Indonesian government gave notice of termination in 2004 and refused to discuss the matter. Currently there are no negotiations taking place between Mauritius and Indonesia.
In August 2009, India said that it is revising its double taxation avoidance treaties, especially those which were concluded prior to 2004. Its objective is to renegotiate anti-abuse provisions.
The following countries have ratified double-tax treaties with Mauritius:

  • Bangladesh
  • Barbados
  • Belgium
  • Botswana
  • China
  • Congo
  • Croatia
  • Cyprus
  • Egypt
  • France
  • Germany
  • Guernsey
  • India
  • Italy
  • Kuwait
  • Lesotho
  • Luxembourg
  • Madagascar
  • Malaysia
  • Malta
  • Monaco
  • Mozambique
  • Namibia
  • Nepal
  • Oman
  • Pakistan
  • Qatar
  • Rwanda
  • Senagal
  • Seychelles
  • Singapore
  • South Africa
  • Sri Lanka
  • Swaziland
  • Sweden
  • Thailand
  • Tunisia
  • Uganda
  • United Arab Emirates
  • United Kingdom
  • Zambia
  • Zimbabwe

In addition, Australia and Mauritius have signed a tax and information exchange agreement. The following territories have agreed treaties with Mauritius but the treaties are awaiting ratification:

 

  • Cape Verde
  • Gabon
  • Ghana
  • Jersey
  • Kenya
  • Morocco
  • Nigeria
  • Russia

There are four territories with treaties awaiting signature: Gambia, Gibraltar, Ivory Coast and Malawi.

The following territories are in the process negotiating tax treaties with Mauritius:

  • Algeria
  • Burkina Faso
  • Canada
  • Czech Republic
  • Greece
  • Hong Kong
  • Iran
  • Mali
  • Montenegro
  • Portugal
  • Saudi Arabia
  • St Kitts and Nevis
  • Tanzania
  • Vietnam
  • Yemen

 

Latest Mauritius Treaty Updates

Treaty Update: Mauritius - Kenya
24 October, 2019
Mauritius and Kenya signed a DTA Protocol on October 16, 2019.
Treaty Update: Comoros - Mauritius
17 September, 2018
On September 12, 2018, Comoros and Mauritius signed a DTA.
Treaty Update: United Kingdom - Mauritius
25 July, 2018
On July 13, 2018, an amending protocol signed in February between the United Kingdom and Mauritius entered into force.
Treaty Update: Mauritius - Barbados
14 May, 2018
The Mauritius Revenue Authority on March 19, 2018, published Government Notice No. 36 of 2018, confirming the entry into force of a Protocol updating its DTA with Barbados.
Treaty Update: United Kingdom - Mauritius
09 March, 2018
The UK and Mauritius signed a DTA on February 28, 2018.
Treaty Update: Cyprus - Mauritius
26 October, 2017
Cyprus and Mauritius signed a DTA Protocol on October 23, 2017.
Treaty Update: Mauritius - Ghana
16 March, 2017
Mauritius and Ghana signed a DTA on March 10, 2017.
Treaty Update: Jersey - Mauritius
09 March, 2017
Jersey and Mauritius signed a DTA on March 3.
Treaty Update: India - Mauritius
25 August, 2016
On August 10, 2016, India completed its domestic ratification procedures in respect of the DTA Protocol signed with Mauritius.
Treaty Update: Mauritius - Korea, South
24 August, 2016
The Mauritian Government has announced that, on August 11, a tax information exchange agreement was signed with South Korea.
Treaty Update: Mauritius - Morocco
07 December, 2015
Mauritius and Morocco signed a DTA on November 25, 2015.
Treaty Update: Mauritius - Sudan
22 October, 2015
According to preliminary media reports, Mauritius has newly indicated that it is negotiating a DTA with North Sudan.
Treaty Update: Mauritius - India
06 July, 2015
Mauritius and India held two days of meetings, concluding on June 30, 2015, on a draft Protocol put forward by Mauritius to amend their DTA.
Treaty Update: South Africa - Mauritius
25 June, 2015
South Africa completed its domestic ratification procedures in respect of the DTA with Mauritius on June 17, 2015, publishing a notification in its Official Gazette. The DTA entered into force on May 28, 2015, and it will be effective from January 1, 2016.
Treaty Update: Mauritius - Swaziland
16 January, 2015
Mauritius signed a renegotiated DTA with Swaziland on November 11, 2014.
Treaty Update: Congo, Republic of the - Mauritius
11 November, 2014
According to preliminary media reports, the DTA between the Republic of the Congo and Mauritius entered into force on October 8, 2014.
Treaty Update: Mauritius - Malta
03 November, 2014
Mauritius and Malta signed a DTA on October 15, 2014.
Treaty Update: Congo, Republic of the - Mauritius
02 September, 2014
According to preliminary media reports, the Republic of Congo completed its domestic ratification procedures on August 7, 2014, in respect of the DTA signed with Mauritius.
Treaty Update: Mauritius - Rwanda
25 August, 2014
The DTA between Mauritius and Rwanda entered into force on August 4, 2014.
Treaty Update: Guernsey - Mauritius
07 July, 2014
The DTA signed between Guernsey and Mauritius on December 17, 2013, will become effective on July 27, 2014.
Treaty Update: Mauritius - Ghana
27 May, 2014
Mauritius and Ghana agreed to launch negotiations towards a DTA on May 22, 2014.
Treaty Update: Luxembourg - Mauritius
31 January, 2014
According to preliminary media reports, Luxembourg and Mauritius signed a DTA Protocol on January 28, 2014.
Treaty Update: Mauritius - United States
15 January, 2014
Mauritius and the United States signed a TIEA and an inter-governmental agreement on December 27, 2013.
Treaty Update: Rwanda - Mauritius
18 November, 2013
The new DTA signed between Rwanda and Mauritius was forwarded to Rwanda's parliament during the week ending November 10, 2013, for ratification, Rwanda's embassy in Kenya has reported.
Treaty Update: Mauritius - Zambia
09 October, 2013
Mauritius has reported successful negotiations towards a DTA with Zambia during a five-day process, which concluded on September 27, 2013. At the conclusion of the meetings, the two parties agreed to soon sign and ratify the agreed pact.
More on TreatyPro.com

 

 

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