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Protocol to India-Mauritius DTAA introducing Principal Purpose Test notified
This Tax Alert summarizes the Notification[1] issued by the Government of India (GOI), dated 13 October 2026, giving effect to the Protocol (2026 Protocol) signed on 7 March 2024. The 2026 Protocol amends India-Mauritius Double Taxation Avoidance Agreement (DTAA or treaty) to incorporate the Base Erosion and Profit Shifting (BEPS) related anti-abuse provisions viz. the preamble and the Principal Purpose Test (PPT), which will act as means to deny treaty benefits if one of the principal purposes of the arrangement or transaction is to obtain the DTAA benefit inconsistent with the object and purpose of the treaty.
The 2026 Protocol has entered into force and is effective from 10 August 2026.
[1] F. No. 135/2026/F. No. 500/03/2012-FTD-II