A summary of the features of the Double Taxation Avoidance Treaties
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.
(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.
(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.