The protocol will enter into force once the countries have taken the necessary steps, and would be "without regard to when the taxes are levied or to the tax years to which the taxes relate".
The new protocol :
- states that it is the intention of both Parties to eliminate double taxation with respect to taxes on income and on capital, without creating opportunities for non-taxation or for reduced taxation through fraud or tax evasion ;
- and provides that any advantage granted under the Agreement shall not be granted if it can reasonably be concluded that the obtaining of the advantage was one of the main purposes of an arrangement or transaction (unless it is established that the granting of the advantage in such circumstances would be consistent with the object and purpose of the relevant provisions of the Agreement).
For further information, please contact your local Mauritius office: office@rosemont.mu