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:

• 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

• 5 treaties await signature : Botswana (New), Gibraltar, Guyana, Malawi and The Gambia

• 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

• 5 protocols to existing treaties awaiting signature: Bangladesh, India, Jersey, Mozambique and Uganda

• 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

1. 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.

2. within any 12-month period

3. within any 24-month period

4. no specific provision made in respect of furnishing of services.

Tax Information Exchange Agreements (TIEAs)

In Force:

• Australia
• Austria
• Denmark
• Faroe Island
• Finland
• Greenland
• Korea
• Norway
• States of Guernsey
• Iceland
• US

Await signature:

Argentina, Greece, Isle of Man

Memorandum of Understanding (MOU)

• MOU between MRA and SARS concerning Avoidance of Double Taxation and Fiscal Evasion

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

MAURITIUS COMPETENT AUTHORITY FOR MUTUAL AGREEMENT PROCEDURES (“MAP”)

Correspondence for the Mauritius competent authorities for all MAP requests should be addressed to:

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