Treaty anti-abuse rules restrict tax benefits where arrangements principally pursue treaty relief without qualifying substantive operations. India-Mauritius tax treaty amendments create a service permanent establishment where services continue beyond the prescribed duration and cap source-State ... Summary
Treaty anti-abuse rules restrict tax benefits where arrangements principally pursue treaty relief without qualifying substantive operations.
India-Mauritius tax treaty amendments create a service permanent establishment where services continue beyond the prescribed duration and cap source-State taxation of qualifying interest and technical-service fees. Capital gains from shares acquired from 1 April 2017 may be taxed in the company's State of residence, subject to transitional rate limits and limitation-of-benefits conditions for genuine business operations. The amendments also permit taxation of certain other income, strengthen exchange of information, provide mutual tax-collection assistance, and introduce a principal purpose test that denies treaty benefits for arrangements principally designed to obtain them contrary to the treaty's object and purpose.
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