The Ministry of Finance, Department of Revenue, on October 13, 2026, has notified the Protocol amending the India–Mauritius Convention for the avoidance of double taxation and the prevention of fiscal evasion.
The following has been stated:
The Protocol, signed on March 7, 2024, entered into force on August 10, 2026, following completion of the required procedures by both countries.
The preamble of the Convention has been amended to emphasise elimination of double taxation while preventing non-taxation, reduced taxation, tax evasion, tax avoidance and treaty-shopping arrangements.
A new Article 27B – Entitlement to Benefits has been introduced. Treaty benefits may be denied where, considering all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the relevant Convention provisions.
The Protocol applies from its date of entry into force, irrespective of when the taxes are levied or the relevant taxable years relate to.
[S.O. 5611(E).]
