Double Taxation Agreements

Mauritius has focused the development of its global business sector on asset protection coupled with its continuously expanding Double Taxation Agreement (“DTA”) Network. With a widespread treaty network, Mauritius offers investors greater opportunities to plan their investments abroad through the use of the Global Business Company Category 1.


The DTA network provides for interesting tax planning opportunities thereby enhancing the image of the jurisdiction as a tax planning centre.

The attractive concessions provided by those treaties include:
  • Elimination of double taxation through tax credit equivalent to Mauritian tax.
  • Reduction in withholding taxes on dividends, interest and royalties.
  • Exemption from capital gains.
  • Possible exemption on interest payments on loans.


Country
Perm. Est.#
Min. Duration
Activity (Mts)
Dividends
Portfolio
Dividends
Others
Interest
Royalties
Capital
Gains~
Barbados65%5%5%5%(d)
Belgium65% (b)10%10%(e)(d)
Botswana125% (a)10%12%12.5%(d) (h)
China125%5%10%10%(d) (g)
Croatia12(e)(e)(e)(e)(d)
Cyprus12(e)(e)(e)(e)(d)
France65% (b)15%(c)15%(d)
Germany65% (a)15%(c)15%(d) (g)
India95% (a)15%(c) 15%(d)
Italy65% (a) (k)15% (k)(c)15%(d)
Kuwait9(e)(e)5% (e) (m)10%(d)
Lesotho610%10%10%10%(d)
Luxembourg65% (b) (i)10% (b) (i)(e)(e)(d)
Madagascar65%10%10%5%(d)
Malaysia65% (b) (j)15% (j) 10%15%(d)
Mozambique68% (a), 10% (b)¹15%8%5%(d)
Namibia65% (a)10%10%5%(d)
Nepal65%(a)², 10% (b)15%15%15% (1)(d)
Oman6(e)(e)(e)(e)(d)
Pakistan610%10%10%12.5%(d)
Quatar
6
(e)(e)(e)5%
(d)
Rwanda12(e)(e)(e)(e)(d)
Senegal9(e)(e)(e)(e)(d)
Seychelles12(e)(e)(e)(e)(d)
Singapore9(e)(e)(e)(e)(d)
South Africa95% (b)15%(e)(e)(d)
Sri Lanka610% (b)15%10%10%(d) (g)
Swaziland67.5%7.5%5%7.5%(d)
Sweden65% (b)15%10%15%(d) (h)
Thailand610%10%15%5% (1), 15%(d)
Tunisia
12
(n)
(n)2.5%2.5%(d)
Uganda610%10%10%10%(d)
United Arab Emirates
12
(e)(e)(e)(e)(d)
UK6
10% (b)15%(c)15%(d)
Zimbabwe6
10% (a)20%10%15%(d) (g)


General Notes
  • Dividends, interests and royalties derived from Mauritius by offshore entities are tax exempt. No capital gains
  • Double Taxation is eliminated by the credit method, i.e. the taxpayer's country of residence will grant a credit for taxes paid in the source country.
  • When a resident of Mauritius is a recipient of dividends from a company which is a resident of the treaty country, the recipient is entitled to a tax credit which shall take into account the tax paid in the treaty country by the company paying the dividend in respect of the profits out of which the dividend is paid.
  • Dividends, interests and royalties derived from Mauritius by offshore entities are tax exempt. There is also no capital gains tax in Mauritius.

*    Recipient is the beneficial owner of the dividends/interest/royalties. Such income is taxed in the recipient' s country of residence but may also be taxed in source country according to the laws of that state.
~     A resident of Mauritius receiving will be allowed a tax credit corresponding to the amount of tax levied in the treaty country.
#    Services and activities including building site or construction, installation or assembly project.


Specific Notes
(a) Shareholding at least 25%,    (a)¹ Shareholding at least 20%    (a)² Shareholding at least 15%
(b) Shareholdings at least 10%    (b)¹Shareholding less than 25%  

(c) Interest taxed in the recipient' s country of residence but may also be taxed in source country according to the laws of that state.

(d) Gains from the alienation of property (movable & immovable) forming part of the business property of a permanent establishment may be taxed in the country where the permanent establishment is situated. Gains from the alienation of ships or aircraft are taxable in the state in which the alienator is resident.

(e) Dividends/Interest/Royalties are taxable only in the recipient's country of residence according to the laws of the state.

(f) Treaty applicable only for Global Business companies.

(g) Gains from the alienation of shares of a company may be taxed in the company's country of residence.

(h) Gains from the alienation of any property (inc. shares) derived by an individual holding dual residence are subject to taxation at any time during the next ten years following the date on which the individual has ceased to be a resident of the first state of which he was a resident.

(i) Dividends derived by a company resident in Luxembourg from Mauritian sources are exempt from tax in Luxembourg provided that the Luxembourg company holds at least 10% of the shareholding of the Mauritian company and that the latter is subjected to tax of at least 15% in Mauritius.

(j) Dividends paid by a company which is resident of Malaysia to a resident of Mauritius who is the beneficial owner are exempt from any tax in Malaysia which is chargeable on dividends.

(k) Such tax shall be deemed to have been paid at an amount not exceeding 15% of the gross amount of the dividends.

(l) In the case of copyright of literary, artistic or scientific work, excluding cinematographic films, tapes or discs for radio or television broadcasting.

(m) In the case of interest paid being effectively connected with a permanent establishment, the beneficial owner of the interest is taxed at a maximum of 5%.

(n) Dividends payable from one state to the other are exempt from tax in both countries, provided that there is no permanent establishment in the beneficiary state.
   
NOTE: THE INFORMATION PRODUCED ABOVE IS FOR GENERAL GUIDANCE ONLY. SPECIFIC PROFESSIONAL ADVICE MUST BE SOUGHT BEFORE ANY ACTION IS TAKEN.


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