Double Taxation Avoidance Agreements
So far Mauritius has concluded 46 tax treaties and is party to a series of treaties under negotiation. The treaties currently in force are:
Australia (Partial) | Barbados | Belgium |
Botswana | Cabo Verde | Republic of Congo |
Croatia | Cyprus | Egypt |
Estonia | Eswatini (Previously known as "Swaziland") | France |
Germany | Ghana |
Guernsey |
Hong Kong | India | Italy |
Jersey | Kuwait | Lesotho (New) |
Luxembourg | Madagascar | Malaysia |
Malta | Monaco | Mozambique |
Namibia | Nepal | Oman |
Pakistan | People's Republic of Bangladesh | People's Republic of China |
Rwanda (New) | Seychelles | Singapore |
Sri Lanka | South Africa (New) | State of Qatar |
Sweden (New) | Thailand | Tunisia |
Uganda | United Arab Emirates | United Kingdom |
Zimbabwe |
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7 treaties await ratification (awaiting the required notification regarding the entering into force of the Agreement as set out in the Article [Entry into force] of the DTAA) : Gabon, Comoros Islands, Kenya, Morocco, Nigeria, Russia and The Republic of Angola
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5 treaties await signature : Botswana (New), Gibraltar, Guyana, Malawi and The Gambia
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20 treaties being negotiated : Algeria, Burkina Faso, Canada, Cote D'Ivoire, Czech Republic (New), Greece, Montenegro, Republic of Sudan, Portugal, Republic of Iran, Saudi Arabia, Senegal (New), Spain, St. Kitts & Nevis, Tanzania, Vietnam, Yemen, Zambia (New), Mali and Republic of Turkey
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5 protocols to existing treaties awaiting signature: Bangladesh, India, Jersey, Mozambique and Uganda
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1 protocol to existing treaties being negotiated : Oman
- 2 treaties have been terminated : Senegal and Zambia
Senegal - Following the termination of the tax treaty between Mauritius and Senegal and in accordance with Article 29 thereof, the treaty will be applicable for the last time, in the case of Mauritius, for the fiscal year ended 30 June 2020 and, in the case of Senegal, for the calendar year ended 31 December 2020.
Zambia - Following the termination of the tax treaty between Mauritius and Zambia and in accordance with Article 28 thereof, the treaty will be applicable for the last time, in the case of Mauritius, for the fiscal year ended 30 June 2021 and, in the case of Zambia, for the calendar year ended 31 December 2020.
Note : * Lesotho - Following the coming into force of the new tax treaty between Mauritius and Lesotho and in accordance with Article 28 of the tax treaty between Mauritius and Lesotho, the treaty will be applicable for the last time, in the case of Mauritius, for the income year ended 30 June 2022 and, in the case of Lesotho, for the assessment year ended 31 March 2022.
Highlights of Mauritius Tax Treaties
Country | Duration to constitute permanent establishment | Maximum tax rates applicable in the State of Source | ||||
Building Site etc | Furnishing of services | Dividends | Interest(i) | Royalties | ||
1 | Australia (Partial) | - | - | - | - | - |
2 | Barbados | 6 months | (iv) | 5% | 5% | 5% |
3 | Belgium | > 6 months | (iv) | 5% & 10% | 10% | Exempt |
4 | Botswana | > 6 months | > 6 months (ii) | 5% & 10% | 12% | 12.5% |
5 | Cabo Verde | >183 days | > 183 days | 5% | 10% | 7.5% |
6 | China | > 12 months | > 12 months(iii) | 5% | 10% | 10% |
7 | Congo | > 12 months | > 12 months | 0% & 5% | 5% | Exempt |
8 | Croatia | > 12 months | (iv) | Exempt | Exempt | Exempt |
9 | Cyprus | > 12 months | > 9 months (ii) | Exempt | Exempt | Exempt |
10 | Egypt | > 6 months | > 6 months | 5% & 10% | 10% | 12% |
11 | Estonia | > 12 months | > 6 months | 0% & 7% | 0% & 7% | 0% & 5% |
12 | Eswatini (Previously known as "Swaziland") | > 6 months | > 6 months(ii) | 7.5% | 5% | 7.5% |
13 | France | > 6 months | (iv) | 5% & 15% | same rate as under domestic law | 15% |
14 | Germany (new) | > 12 months | (iv) | 5% & 15% | Exempt | 10% |
15 | Ghana | > 6 months | > 6 months (ii) | 7% | 7% | 8% |
16 | Guernsey | > 12 months | > 9 months | Exempt | Exempt | Exempt |
17 | Hong Kong | > 6 months | > 6 months | 0% & 5% | 5% | 5% |
18 | India | > 9 months | > 3 months | 5% & 15% | 7.5% | 15% |
19 | Italy | > 6 months | (iv) | 5% & 15% | same rate as under domestic law | 15% |
20 | Jersey | > 12 months | > 9 months | Exempt | Exempt | Exempt |
21 | Kuwait | > 9 months | (iv) | Exempt | Exempt | 10% |
22 | Lesotho (New) | > 6 months | > 4 months | 10% | 10% | 10% |
23 | Luxembourg | > 6 months | (iv) | 5% & 10% | Exempt | Exempt |
24 | Madagascar | > 6 months | (iv) | 5% & 10% | 10% | 5% |
25 | Malaysia | > 6 months | (iv) | 5% & 15% | 15% | 15% |
26 | Malta | > 12 months |
> 12 months |
Exempt | Exempt | Exempt |
27 | Monaco | > 12 months |
> 12 months |
Exempt | Exempt | Exempt |
28 | Mozambique | > 6 months | > 6 months (ii) | 8%, 10% & 15% | 8% | 5% |
29 | Namibia | > 6 months | > 6 months (ii) | 5% & 10% | 10% | 5% |
30 | Nepal | > 6 months | > 6 months (ii) | 5%, 10% & 15% | 10% & 15% | 15% |
31 | Oman | > 6 months | (iv) | Exempt | Exempt | Exempt |
32 | Pakistan | > 6 months | (iv) | 10% | 10% | 12.5% |
33 | Rwanda | > 6 months | > 6 months | 10% | 10% | 10% |
34 | People's Republic of Bangladesh | >12 months | > 12 months | 10% | normal rate | normal rate |
35 | Seychelles | > 12 months | > 6 months (ii) | Exempt | Exempt | Exempt |
36 | Singapore | > 9 months | (iv) | Exempt | Exempt | Exempt |
37 | South Africa | > 12 months | > 6 months (ii) | 5% & 10% | 10% | 5% |
38 | Sri Lanka | > 6 months | > 6 months (ii) | 10% & 15% | 10% | 10% |
39 | State of Qatar | > 6 months | > 6 months (ii) | Exempt | Exempt | 5% |
40 | Sweden (New) | > 12 months | (iv) | 0% & 15% | Exempt | Exempt |
41 | Thailand | > 6 months | > 6 months (ii) | 10% | 10% & 15% | 5% & 15% |
42 | Tunisia | > 12 months | (iv) | Exempt | 2.5% | 2.5% |
43 | Uganda | > 6 months | > 4 months (ii) | 10% | 10% | 10% |
44 | United Arab Emirates | > 12 months | > 12 months | Exempt | Exempt | Exempt |
45 | United Kingdom | > 6 months | (iv) | Exempt & 15% | Same rate as under domestic law | 15% |
46 | Zimbabwe | > 6 months | (iv) | 10% & 20 % | 10% | 15% |
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where interest is taxable at rate provided in the domestic law of the State of source or at reduced treaty rate, provision is usually made in the treaty to exempt interest receivable by a Contracting State itself, its local authorities, its Central Bank/all banks carrying on bona fide banking business and any other financial institutions as may be agreed upon by both Contracting States.
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within any 12-month period
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within any 24-month period
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no specific provision made in respect of furnishing of services.
Tax Information Exchange Agreements (TIEAs)
In Force:
Await signature:
Argentina, Greece, Isle of Man
Memorandum of Understanding (MOU)
MAURITIUS COMPETENT AUTHORITY AND AUTHORISED REPRESENTATIVES UNDER DOUBLE TAXATION AVOIDANCE AGREEMENT
(24 August 2021)
COMPETENT AUTHORITY
Director-General
Mauritius Revenue Authority
Ehram Court
Cnr Sir Virgil Naz & Mgr Gonin Streets
Port Louis
AUTHORISED REPRESENTATIVES FOR EXCHANGE OF INFORMATION
Department | Title | Name | |
---|---|---|---|
MRA | Director-General | Mr. Sudhamo Lal | - |
Large Taxpayers Department, MRA | Director | Mr. Mamade Faisal Oozeerally | This email address is being protected from spambots. You need JavaScript enabled to view it. |
Large Taxpayers Department, MRA | Team Leader | Mr. Deoraj Juggoo | This email address is being protected from spambots. You need JavaScript enabled to view it. |
Large Taxpayers Department, MRA | Section Head | Mr. Krishna Rambaksh | This email address is being protected from spambots. You need JavaScript enabled to view it. |
Large Taxpayers Department, MRA | Section Head | Mrs. Tayshree Kumaree Goburdhone | This email address is being protected from spambots. You need JavaScript enabled to view it. |
MAURITIUS COMPETENT AUTHORITY FOR MUTUAL AGREEMENT PROCEDURES (“MAP”)
Correspondence for the Mauritius competent authorities for all MAP requests should be addressed to:
Department | Title | Name | Address | |
---|---|---|---|---|
Large Taxpayers Department & International Taxation Unit, MRA | Director | Mr. Mamade Faisal Oozeerally | This email address is being protected from spambots. You need JavaScript enabled to view it. |
Mauritius Revenue Authority |
Large Taxpayers Department & International Taxation Unit, MRA | Section Head | Mr. Krishna Rambaksh | This email address is being protected from spambots. You need JavaScript enabled to view it. |
PLEASE NOTE:
Correspondence for the Mauritius competent authority for all exchange of information matters should be addressed to:
Mr. Mamade Faisal Oozeerally
Director
Large Taxpayers Department & International Taxation Unit
Mauritius Revenue Authority
Level 5
Ehram Court
Cnr. Sir Virgil Naz & Mgr Gonin Streets
Port Louis
MAURITIUS