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Mauritius: Double Tax Treaties

Introduction

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

 

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