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Protocol to India-Mauritius DTAA signed to include Principal Purpose Test
This Tax Alert summarizes the amendments to India-Mauritius Double Taxation Avoidance Agreement (DTAA or treaty) vide Protocol signed on 7 March 2024 (2024 Protocol) by India and Mauritius to incorporate the Base Erosion and Profit Shifting (BEPS) related anti-abuse provisions.
The 2024 Protocol proposes to incorporate the minimum standards of anti-abuse provisions, i.e., the Preamble and the Principal Purpose Test (PPT), which will act as a means to deny treaty benefits if one of the principal purposes of the arrangement or transaction is to obtain the DTAA benefit.
The 2024 Protocol will be effective from the date of entry into force, without regard to the date on which the taxes are levied or the taxable years to which taxes relate.