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Utilising Mauritian & Seychelles double tax treaty network for structuring investment abroad

Mauritius and Seychelles have focused the development of their international financial centre on the use of their growing network of double taxation treaties for structuring investment abroad. So far Mauritius has ratified forty four treaties and is party to a series of treaties under negotiation. For more information, read the guide below or contact us directly to find out how we can assist you.

A Guide to the Use of Double Tax Treaties in Mauritius & the Seychelles

Treaties currently in force are with Barbados, Belgium, Botswana, Croatia, Cyprus, France, Germany, India, Italy, Kuwait, Lesotho, Luxembourg, Madagascar, Malaysia, Mozambique, Namibia, Nepal, Oman, Pakistan, People’s Republic of China, Rwanda, Senegal, Seychelles, Singapore, South Africa, Sri Lanka, Swaziland, Sweden, Thailand, Uganda, United Arabs Emirates, United Kingdom and Zimbabwe.

Treaties awaiting ratification include Bangladesh, Malawi, Nigeria, Russia, State of Qatar, Vietnam, Zambia and Tunisia.

The Seychelles have ratified around 8 treaties including South Africa, China, Indonesia and Mauritius.

Tax treaty benefits are only available to resident entities or persons. Accordingly, a resident entity must be liable to tax in Mauritius or Seychelles under its laws by reason of its domicile, residence or criterion of a similar nature. Mauritius provides a wide range of resident entities and hybrid structures including the Global Business Company, the Trust and the Société. Seychelles provides for a CSL company and a domestic company. In Mauritius, a resident company including the Global Business Company may benefit from the tax treaty network. It is also possible for Mauritian branch of a foreign company to access the tax treaties by satisfying the conditions of residence. Entities wishing to avail benefits of a tax treaty must obtain a Tax Residence Certificate issued by the Mauritius Revenue Authority in Mauritius and same applies in the Seychelles.

All Mauritian double taxation avoidance treaties are based on the OECD Model Treaty of 1977. Under the post-independence treaties concluded so far, tax sparing is available. This implies that where Mauritian source dividends are exempt from tax under the tax incentive provisions, the foreign investor is entitled to credit a notional amount of Mauritian tax against the tax payable (if any) in his country, thus reducing his domestic tax liability.

All Seychelles double taxation avoidance treaties are based on either the OECD Model Treaty or the United Nations Model Treaty. However no credits are allowed in the Seychelles to reduce the domestic tax liability.

If a resident of Mauritius derives income from a foreign country that has not concluded a tax treaty with Mauritius and foreign income tax is paid on the income, that tax may be credited against Mauritian income tax. The credit is limited on a source-by-source basis to the lesser of the foreign tax paid on the income concerned and the Mauritian income tax payable on the same income. In the case of foreign source dividends, no credit relief if granted for foreign corporate income tax borne on the profits out of which the dividends are paid (underlying tax). This does not apply for the Seychelles, because the credit method is not used.

How to proceed

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OCRA Worldwide announces strategic merger with Acclime

17th November 2022, Hong Kong - OCRA Worldwide (OCRA), announces today that it has completed the strategic merger with Asia Pacific’s premier corporate services provider Acclime (www.acclime.com). This is the latest step in Acclime’s active expansion as the Asia specialist in compliance and corporate services throughout the region.

Established in 1975 and led by Bart Dekker and Dharmesh Naik, OCRA is one of the industry pioneers in the corporate services sector with a full suite of corporate services from company formation, company secretarial support, accounting, and HR services. Over the past 40 years, OCRA has become a truly global business by providing very personalised services to their clients, most of whom are private investors or companies investing abroad.

From its founding base in Europe, OCRA has morphed over the past decade to focus on the faster growing markets of Asia and the Indian Ocean, and currently has teams in Hong Kong, Shanghai, Singapore, Mauritius and the Seychelles with around 80 staff. Additionally, OCRA is licensed in Samoa and the UAE to provide incorporation services to clients and referral partners.

"The high quality of the team, the interesting gateway jurisdictions of Mauritius and UAE which are important investment hubs for Africa and India, and the synergy of offering OCRA clients more services and Asian locations for expanding their business were the strategic logic for Acclime's interest in acquiring OCRA," said Martin Crawford, CEO and Co-Founder of Acclime. "We look forward to introducing OCRA’s corporate clients to our regional experts in China, Hong Kong, Australia, Cambodia, Indonesia, Malaysia, Thailand, India, Philippines, Singapore and Vietnam," he added.

The sale of the business was managed by the corporate advisory team of Mazars in London (Paul Joyce & Fred Dearden), acting for the ultimate shareholder of OCRA, and was opened for bids. "Acclime was chosen as the preferred bidder as the team recognised the cultural similarities, with high quality, personalised services at the core," said Bart Dekker, OCRA’s Managing Director, Asia Pacific. Dharmesh Naik, OCRA's Managing Director, Middle East and Indian Ocean, added, "We are excited and delighted to become an integral part of a large international team with the established resources across Acclime's network, and to execute the transaction in line with OCRA's long term succession plan in the interest of all of our stakeholders."

OCRA will operate as an independent business unit within Acclime, supported by funding, IT and marketing initiatives that will grow the business further. Bart Dekker and Dharmesh Naik will remain running the business post-acquisition.

The transaction is subjected to regulatory approvals in several locations and Acclime is expected to complete the acquisition by the end of 2022.

About OCRA
Established in 1975, OCRA is one of the industry pioneers in the corporate services sector with a full suite of corporate services from company formation, company secretarial support, accounting and HR services. For over 40 years, OCRA has been providing personalised services to its clients, most of whom are private investors or companies investing abroad.

About Acclime
Acclime, the premier corporate services provider in Asia, helps corporate and private clients to advance their businesses and interests in difficult-to-navigate markets in emerging Asia. The company’s vision is to reinvent the corporate services sector with innovative solutions that are seamlessly delivered to the highest global standards.

Enquiries: enquiries@ocra.com