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DOUBLE TAXATION AVOIDANCE TREATIES SUMMARY TABLE

   
No Year
Signed		 Entry
into
Force		 Country Tax
Sparing
Clause		 Royalties
(Max.
Rate)		 Dividends Interests Permanent Establishment Capital Gains
Portfolio Other Banks Other Min Duration
Activity (months)
1 1978 30/11/90 Germany No 15% 5% (a) 15% Exempt (c) 6 (d) (g)
2 1981 17/10/82 France No 15% 5% (b) 15% (e) (c) 6 (d)
3 1981 26/10/87 United Kingdom Yes 15% 10% (b) 15% (c) (c) 6 (d)
4 1983 11/06/85 India Yes 15% 5% (b) 15% Exempt (c) 9 (d)
5 1992 28/08/92 Zimbabwe Yes 15% 10% (a) 20% 10% 10% 6 (d) (g)
6 1992 21/12/92 Sweden (f) Yes 15% 5% (b) 15% 10% 10% 6 (d) (h)
7 1993 17/08/93 Malaysia Yes 15% 5%(b)(j) 15%(j) 10% 10% 6 (d)
8 1994 08/11/94 Swaziland Yes 7.5% 7.5% 7.5% 5% 5% 6 (d)
9 1990 28/04/95 Italy No 15% 5%(a)(k) 15%(k) (c) (c) 6 (d)
10 1994 05/05/95 China Yes 10% 5% 5% Exempt 10% 12 (d)(g)
11 1994 01/07/95 Pakistan Yes 12.5% 10% 10% 10% 10% 6 (d)
12 1994 04/12/95 Madagascar No 5% 5% 10% 10% 10% 6 (d)
13 1995 07/06/96 Singapore Yes Exempt Exempt Exempt Exempt Exempt 9 (d)
14 1995 13/03/96 Botswana Yes 12.5% 5%(a) 10% 12% 12% 12 (d)(h)
15 1995 25/07/96 Namibia Yes 5% 5%(a) 10% Exempt 10% 6 (d)
16 1995 12/09/96 Luxembourg Yes Exempt 5%(b)(i) 10%(b)(i) Exempt Exempt 6 (d)
17 1996 02/05/97 Sri Lanka Yes Exempt 5%(b) 10% Exempt Exempt 183 days (d)(g)
18 1996 20/06/97 South Africa Yes Exempt 5%(b) 10% Exempt Exempt 9 (d)
19 - - United Arab Emirates - Exempt Exempt Exempt Exempt Exempt 12 (d)
20 1997 10/06/98 Thailand Yes 5%(1)15% 10% 10% 10% 15% 6 (d)
21 1998 20/07/98 Oman Yes Exempt Exempt Exempt Exempt Exempt 6 (d)
22 1997 01/08/98 Kuwait Yes 10% (e) (e) (e)(m) (e)(m) 9 (d)
23 1995 28/01/99 Belgium Yes Exempt 5%(b) 10% 10% 10% 6 (d)
24 1997 08/04/99 Mozambique Yes 5% 8%(a)10%(b)1 15% Exempt 8% 6 (d)
25 1999 10/11/99 Nepal Yes 15%(1) 5%(a)2,10%(b) 15% 10% 15% 6 (d)
26 2000 12/06/00 Cyprus Yes Exempt Exempt Exempt Exempt Exempt 12 (d)
27 2003 10/08/03 Croatia - Exempt Exempt Exempt Exempt Exempt 12  
28 - - Lesotho - 10% 10% 10% 10% 10% 6  
29 - - Seychelles - Exempt Exempt Exempt Exempt Exempt 12  
30 2003 14/04/03 Rwanda - Exempt Exempt Exempt Exempt Exempt 12  
31 2003 17/11/03 Senegal - Exempt Exempt Exempt Exempt Exempt 9  
32 2003 - Uganda - 10% 10% 10% 10% 10% 6  
33   - Barbados - 5% 5% 5% 5% 5% 6  

 

A summary of the features of the Double Taxation Avoidance Treaties

General Notes

  • Dividends, interests and royalties derived from Mauritius by Offshore entities are tax exempt. No capital gains.
  • Double taxation is eliminated by the credit method, i.e., the taxpayer's country of residence will grant a credit for taxes paid in the source country.
  • When a resident of Mauritius is recipient of dividends from a company which is resident of the treaty country, the resident is entitled to a tax credit which shall take into account the tax paid in the treaty country by the company paying the dividend in respect of the profits out of which the dividend is paid.
Recipient is the Beneficial Owner of the dividends/interests/royalties. Such income is taxed in the recipient's country of residence but may also be taxed in source country according to the laws of that state.

A resident of Mauritius receiving dividends/interests/royalties will be allowed to a tax credit corresponding to the amount of tax levied in the treaty country.

Permanent Establishment: Services and activities including building site or a construction, installation or assembly project.


Specific Notes

(a)  Shareholding at least 25%, (a)1 Shareholding at least 20% (a)2 Shareholding at least 15%

(b) Shareholding at least 10% (b)1 Shareholding less than 25%

(c) Interest taxed in recipient's country of residence but may also be taxed in source country according to the laws of that state.

(d) Gains from the alienation of property (movable & immovable) forming part of the business property of a permanent establishment may be taxed in the country where the permanent establishment is situated. Gains from alienation of ships or aircraft are taxable in the state in which the alienator is resident.

(e) Dividends/Interests/Royalties are taxable only in the recipient's country of residence according to the laws of the state.

(f) Treaty applicable only for Offshore Companies.

(g) Gains from the alienation of shares of a company may be taxed in the company's country of residence.

(h) Gains from alienation of any property (inc. shares) derived by an individual holding "dual" residence are subject to taxation at any time during the next ten years following the date on which the individual has ceased to be a resident of the first state of which he was a resident.

(i) Dividends derived by a company resident in Luxembourg from Mauritian sources are exempt from tax in Luxembourg provided that the Luxembourg company holds at least 10% of the shareholding of the Mauritian company and that the latter is subjected to tax of at least 15% in Mauritius.

(j) Dividends paid by a company which is resident of Malaysia to a resident of Mauritius who is the beneficial owner are exempt from any tax in Malaysia which is chargeable on dividends.

(k) Such tax shall be deemed to have been paid at an amount not exceeding 15% of the gross amount of the dividends.

(l) In the case of copyright of literary, artistic or scientific work, excluding cinematographic films, tapes or discs for radio or television broadcasting.

(m) In the case of interest paid being effectively connected with a permanent establishment, the beneficial owner of the interest is taxed at a maximum of 5%.
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