Double Taxation Avoidance Agreements


So far Mauritius has concluded 45 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

Congo

Croatia Cyprus Egypt
Estonia

Eswatini (Previously known as "Swaziland")

France

Germany (New)

Ghana

Guernsey

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

Seychelles

Singapore

Sri Lanka

South Africa (New)

State of Qatar

Sweden (New)

Thailand

Tunisia

Uganda

United Arab Emirates

United Kingdom

Zimbabwe

 

  • 6 treaties await ratification : Gabon, Comoros Islands, Kenya (awaiting the required notification from Kenya regarding the entering into force of the Agreement as set out in Article 28 (Entry Into Force) of the DTAA), Morocco, Nigeria and Russia

  • 5 treaties await signature : Cote D'Ivoire, Gibraltar, Malawi, The Gambia and The Republic of Angola

  • 20 treaties being negotiated : Algeria, Burkina Faso, Canada, Czech Republic, Greece, Hong Kong, Montenegro, North Sudan, Portugal, Republic of Iran, Saudi Arabia, Senegal (New), Spain, St. Kitts & Nevis, Tanzania, Vietnam, Yemen, Zambia (New), Mali and Republic of Turkey (New)

  • 4 protocols to existing treaties being negotiated : Germany, Mozambique, Pakistan and Uganda

  • 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 India > 9 months > 3 months 5% & 15% 7.5% 15%
18 Italy > 6 months (iv) 5% & 15% same rate as under domestic law 15%
19 Jersey > 12 months > 9 months Exempt Exempt Exempt
20 Kuwait > 9 months (iv) Exempt Exempt 10%
21 Lesotho (New) > 6 months > 4 months 10% 10% 10%
22 Luxembourg > 6 months (iv) 5% & 10% Exempt Exempt
23 Madagascar > 6 months (iv) 5% & 10% 10% 5%
24 Malaysia > 6 months (iv) 5% & 15% 15% 15%
25 Malta > 12 months

> 12 months

Exempt Exempt Exempt
26 Monaco > 12 months

> 12 months

Exempt Exempt Exempt
27 Mozambique > 6 months > 6 months (ii) 8%, 10% & 15% 8% 5%
28 Namibia > 6 months > 6 months (ii) 5% & 10% 10% 5%
29 Nepal > 6 months > 6 months (ii) 5%, 10% & 15% 10% & 15% 15%
30 Oman > 6 months (iv) Exempt Exempt Exempt
31 Pakistan > 6 months (iv) 10% 10% 12.5%
32 Rwanda > 6 months > 6 months 10% 10% 10%
33 People's Republic of Bangladesh >12 months > 12 months 10% normal rate normal rate
34 Seychelles > 12 months > 6 months (ii) Exempt Exempt Exempt
35 Singapore > 9 months (iv) Exempt Exempt Exempt
36 South Africa > 12 months > 6 months (ii) 5% & 10% 10% 5%
37 Sri Lanka > 6 months > 6 months (ii) 10% & 15% 10% 10%
38 State of Qatar > 6 months > 6 months (ii) Exempt Exempt 5%
39 Sweden (New) > 12 months (iv) 0% & 15% Exempt Exempt
40 Thailand > 6 months > 6 months (ii) 10% 10% & 15% 5% & 15%
41 Tunisia > 12 months (iv) Exempt 2.5% 2.5%
42 Uganda > 6 months > 4 months (ii) 10% 10% 10%
43 United Arab Emirates > 12 months > 12 months Exempt Exempt Exempt
44 United Kingdom > 6 months (iv) Exempt & 15% Same rate as under domestic law 15%
45 Zimbabwe > 6 months (iv) 10% & 20 % 10% 15%

 

  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:

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

DepartmentTitle NameEmail
MRA Director-General Mr. Sudhamo Lal -
MRA Technical Adviser to Director-General Mr. Michel Mario Hannelas This email address is being protected from spambots. You need JavaScript enabled to view it.
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.

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