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of <h1>Mauritius DTAA Article 27A: Limits Benefits for Shell Companies Exploiting Tax Agreements; Defines Shell Entities and Exceptions.</h1> Article 27A of the Double Tax Avoidance Agreement (DTAA) between Mauritius and another Contracting State outlines limitations on benefits. It denies benefits under Article 13(3B) if a resident's arrangements primarily aim to exploit these benefits. Shell or conduit companies, defined as entities with negligible or no substantial business activities, are also excluded. A company is considered a shell if its operational expenditure in the Contracting State is below Mauritian Rs. 1,500,000 or Indian Rs. 2,700,000 over the previous 12 months. Exceptions include companies listed on recognized stock exchanges or those meeting the specified expenditure threshold.
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