The tax treaty between India and Mauritius was signed in in keeping with India’s strategic interests in the Indian Ocean and India’s close cultural links with . not taxable in India under the provisions of the Double Taxation Avoidance Agreement (tax treaty) between India and Mauritius. In detail. Facts. The country that is next in line is Singapore with a FDI inflow to India in the same period amounting to INR , crores. While Mauritius accounts for 34% of.
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Notwithstanding the provisions of paragraph 2 of this Axticle and Articles 7, 14 and 15, where income is derived from personal activities exercised by an entertainer or an athlete in his capacity as such in a Contracting State and accrues not to the entertiner or athlete himself but to another person, that income shall be taxable only in the Contracting State, if that other persons is supported wholly or substantially from the public funds of that other Contracting State, including any of its political sub-divisions or local authorities.
Interest arising in a Contracting State shall be exempt from tax in that State provided it is derived and beneficially owned by:. A student or business apprentice who is or was a resident of one of the Contracting States immediately before visiting the other Contracting State and who is present in that other Contracting State solely for the purpose of his education or training shall be exempt from tax in that other Contracting State on.
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Notwithstanding the preceding provisions of this article, the term “permanent establishment” shall be deemed not to include: Dividends paid annd a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. The phasing out of such tax benefits in the India Mauritius DTAA would mean that benefits in respect of capital gains from the sale of betwewn in an Indian company netween no longer be available to Singapore residents after the new provisions come into effect on the 1 st of April The term ‘ dividends ‘ as used in this Article means income from shares or other rights, not being debt-claims, participating indiq profits, as well as income from other corporate rights which is subjected to the mauritiue taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident.
If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that nad Contracting State. In such a case, the provisions of article 7 or article 14, as the case may be, shall beween. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and accordingly to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: Notwithstanding the provisions of paragraph 2 of this article and articles 7, 14 and 15, where income is derived from personal dyaa exercised by an entertainer or an athlete in his capacity as such in a Contracting State and accrues not to the entertainer or athlete himself but to another person, that income shall be taxable only in the Contracting State, if that other person is supported wholly or substantially from the public funds of that other Contracting State, including any of its political sub-divisions or local authorities.
Notwithstanding the provisions of paragraph 2dividends paid by a company which is a resident of Mauritius to a resident of India may be taxed in Mauritius and according to the laws of Mauritius, as long as dividends paid by companies which are residents of Mauritius are allowed as deductible expenses for determining their taxable profits.
Article 4 Article 13 Capital Gains of the Convention shall be amended with effect from 1.
The exchange of information is not restricted by Articles 1 and 2. This assistance is not restricted by Article 1 and 2. The betdeen ” resident of India ” and ” resident of Mauritius ” shall be construed accordingly.
EY refers to the global organization and may also denote one or more of the member firms msuritius EY Global Limited, each of which is a separate legal entity. Soon enough, the Indian tax officers did not appreciate the prospect of perceived letter box companies in Mauritius claiming the tax exemptions and sent tax bills to them, alleging misuse of treaty.
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Section 90 is for taxpayers who have paid the tax to a country with which India has signed DTAA, while Section 91 provides relief to tax payers who have paid tax to a country with which India has not signed a DTAA. Where, however, the person paying the interest, whether be is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is home by that permanent establishment, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment is situated.
Toggle navigation Home About Us. Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. Further, where such resident is a company by which surtax is payable in India, the credit aforesaid shall be allowed in the first instance against income-tax payable by the company in India and as to the balance, if any, against surtax payable by it in India.
Gains derived by a resident of beteen Contract State from the alienation of any property other than those mentioned in paragraphs 12 and 3 of this article shall be taxable only in that State.
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However, this exemption shall apply only if such interest arises from debt-claims existing on or before 31 st March, For the purposes of this Convention, unless the context otherwise requires: DONE on this 24th day of August, at Port Louis on two original copies each in Hindi and English languages, both the texts being equally authentic.
Mauritius is the main provider of foreign direct investment FDI to India and also the preferred jurisdiction for Indian outward investments into Africa. Any pension paid by the Government of a Contracting State to an individual who is a national of that State, shall be taxable only in that Contracting State.
Income derived by a resident of a Contracting State in respect of professional services or other independent activities of a similar character shall be taxable only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities.
Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local authority, or a resident of that State.
Article betwen substituted by Notification No. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities in the same circumstances.