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MAURITIUS – HONG KONG DOUBLE TAX AVOIDANCE AGREEMENT IS IN FORCE
Mauritius – Hong Kong Double Tax Avoidance Agreement is in Force Following the ratification procedures by both treaty partners, the The Double Taxation Avoidance Agreement (“DTAA”) between Mauritius and Hong Kong has come into effect as from 23 June 2023. The new DTAA between Mauritius and Hong Kong aims to…
MAURITIUS BUDGET 2023/2024: CHANGES IN PROPERTY OWNERSHIP FOR FOREIGNERS
During the recent Mauritius budget speech for the fiscal year 2023/2024, a range of measures aimed at bolstering the country’s real estate sector and attracting foreign investment were announced. One significant aspect outlined in the budget speech pertains to the changes in property ownership regulations for foreigners. Easing Restrictions on…
MAURITIUS BUDGET 2023/2024: PROPOSED CHANGES TO OCCUPATION/RESIDENCE PERMITS
The budget speech of Mauritius for the fiscal year 2023/2024 has unveiled several significant proposals aimed at fostering economic growth, attracting foreign investment, and enhancing the country’s competitiveness on the global stage. Among the notable changes outlined in the budget speech are the proposed amendments to the occupation permit system.…
MAURITIUS JOINS THE MADRID SYSTEM FOR TRADEMARKS: A MAJOR BOOST FOR BUSINESSES
In a significant move that highlights its commitment to fostering a favourable business environment, on 6 February 2023, Mauritius joined the Madrid System for trademarks administered by the World Intellectual Property Organization (WIPO) making it the 114th member. Of the 114 members, 19 are African countries. This development opens up…
HAS THE TIME COME TO AVOID PURCHASING A HOLIDAY HOME IN SOUTH AFRICA?
The South African Revenue Service (SARS) recently released a set of rules for transferring monies out of South Africa. Currently South Africans who want to transfer funds abroad of more than their R1m annual allowance are required to have a “Tax Clearance Pin”. For “non-residents” however, they will be required…
BENEFITS OF IMMIGRATING TO MAURITIUS
Mauritius, an island nation located in the Indian Ocean, is a popular destination for those looking to emigrate. Here are a few of the benefits of living in this tropical paradise. Stable Economy: Mauritius has a strong and stable economy, which is a major draw for those looking to start…
EUROPEAN COURT RULES AGAINST PUBLIC REGISTERS OF BENEFICIAL OWNERSHIP
A judgement made on 22 November 2022 in a European Court of Justice has ruled against public access to the information on the register of beneficial owners and cited that this “constitutes a serious interference with the fundamental rights to respect for private life and to the protection of personal…
MAURITIUS AND HONG KONG SAR ENTER INTO A DOUBLE TAX AGREEMENT
On 7th November 2022, Hong Kong signed a comprehensive double tax agreement (CDTA) with Mauritius which will enter into force following the completion of the ratification procedures in both jurisdictions. Some of the key features of the CDTA are: Tax Residency An entity shall only be tax resident in the…
MAURITIUS AND ANGOLA – DOUBLE TAX AVOIDANCE AGREEMENT
Mauritius and the Republic of Angola have executed a double taxation avoidance agreement (DTAA) which was published in the gazette of Mauritius on 30 August 2022. The agreement will come into effect on the date that Mauritius receives notification of the completion of the procedures under the domestic laws of…
YACHT CREW EMPLOYMENT
Having chosen the jurisdiction in which to register your yacht you now need to contemplate the issue of crew. With crew based on a yacht where the ownership, registration and homeport may all be different, as well as the fact that the yacht also moves, the issue of crew employment…
IMPORTING HOUSEHOLD AND PERSONAL EFFECTS INTO MAURITIUS
When relocating to Mauritius, a person may benefit from an exemption of tax and duties when importing their household and personal effects. MTrans Movers have put together a detailed article on the conditions of importing your personal effects when relocating permanently to Mauritius. Click here to view the full article.…
WHERE TO REGISTER YOUR YACHT
Having taken the decision to purchase your yacht you will now be faced with the decision as to where to register it. The decision is an important one and it is important to get it right. It would also make sense to talk to an advisor in making that decision…
MAURITIUS FOR AVIATION FUNDING AND LEASING SERVICES IN AFRICA
BACKGROUND Aviation in Africa is often more of a necessity than purely for pleasure, but is growing strongly. The difficulty in moving around Africa without transiting through a European hub has meant that more and more corporates and HNW individuals have purchased their own aircraft. Of interest then is the…
SOUTH AFRICAN PLEASURE YACHT OWNERSHIP
South Africa, with its long coastline and superb weather has had a long association with sailing and the sea. This has continued into supporting some of the larger pleasure yacht manufacturers in the world today. Robertson and Caine and Voyage Yachts inter alia have a large manufacturing capability and has…
KENYA OFFERS ATTRACTIVE TAX INCENTIVES TO ENTITIES OPERATING IN THE TATU CITY SPECIAL ECONOMIC ZONE
We are proud to be associated with Gateway Real Estate Africa (GREA) who are the developers that will be constructing Eneo at Tatu Central, the anchor of the business district in Tatu City, Kenya. Eneo will consist of 2 office towers with a retail sector which will span an impressive…
THE ECONOMIC CRIME (TRANSPARENCY AND ENFORCEMENT) ACT 2022 (THE “ACT”)
On 15 March 2022 the Act was enacted by the UK Parliament to have effect in the United Kingdom. Some parts of the Act are not yet in force, and the supporting regulation has not been published. The purpose of this Act is to: Create a publicly accessible register containing…
THE SARS NON-RESIDENT TAX STATUS CONFIRMATION LETTER AND THE EMIGRATION TAX COMPLIANCE PIN
Expats who have chosen to go through the formal financial immigration process with SARS, on completion of the financial immigration process they are issued with a letter by the South African Revenue Service (SARS) that contains their Emigration Tax Compliance Pin (TCS). A letter which has a validity period of…
MAURITIUS TAX TREATY NETWORK UPDATE
2 new items of news from an ongoing treaty network expansion. Hong Kong Treaty to be signed. On the 1st of April 2022 the Mauritius cabinet authorised the signing of a treaty with Hong Kong. The treaty is in line with the OECD and UN Model Agreements on avoidance of…
RELAXING OF EXCHANGE CONTROL OF REQUIREMENTS FOR CAPITAL TRANSFERS BY PRIVATE INDIVIDUALS RESIDENT IN SOUTH AFRICA.
In the South African 2022 Budget Speech, the minister of Finance announced that the criteria for South African resident individuals who wish to invest abroad, have been expanded upon. The changes as published in Exchange Control Circular No. 8/2022 came into effect on 23 February 2022 in South Africa and…
MAURITIUS EXITS THE EU BLACKLIST
In an official publication released on 7th January 2022, The European Commission has proceeded to withdraw/remove Mauritius from their list of High Risk Third countries (often referred to as the EU Blacklist). The EU commission cited that it is satisfied that Mauritius has met the requirements laid out by the…
MAURITIUS RESIDENCE VISAS – TIME TO CONSIDER THEM
With the new year upon us again it makes sense for you to consider taking advantage of two really beneficial visas offered by Mauritius. Retiree visa One of the easiest visas to obtain in Mauritius. In order to obtain one, you need to be over 50, be able to remit…
MAURITIUS EXISTS THE UK LIST OF HIGH-RISK COUNTRIES
On the 2nd November 2021, the United Kingdom removed Mauritius from its list of high-risk countries under the UK’s Money Laundering and Terrorist Financing (Amendment) (No. 3) (high-risk countries) Regulations 2021. The decision followed shortly after the Financial Action Task Force (FATF) announced at the October 2021 plenary that Mauritius…
MAURITIUS EXITS THE FATF “GREY LIST”
The Financial Action Task Force (FATF) held its October plenary this week, and upon its conclusion on 21st October 2021, it was announced by the president of the FATF, Mr. Marcus Pleyer, that “after completing its action plan and a successful onsite visit by FATF team, Mauritius has been removed…
MAURITIUS ANNOUNCES THE REMOVAL OF THE TRAVEL BAN ON SOUTH AFRICA
After nearly 18 months, borders between South Africa and Mauritius are opening once again and the travel ban on South Africa has been lifted, effective 10th September and commercial flight operations will resume on 1st October 2021. This welcome announcement comes as a large relief to many South Africans who…
AMENDMENTS TO BVI’S PRIVATE TRUST COMPANY REGULATIONS – 2021
The BVI has become the jurisdiction of choice for private trust companies following the introduction of the Financial Services (Exemptions) Regulations, 2007 (as amended, “the PTC Regulations”). Currently there are more than 1000 of these private trust companies that have been established to date. A number of amendments to the…
RETIREMENT IN MAURITIUS AN OVERVIEW
Mauritius has a lot to offer those who are looking for an ideal location to spend their retirement years. With a tropical climate, mountains, beautiful beaches, and clear blue waters, there is something for everyone. In the 2021/2022 budget speech, the Mauritian government announced that they wish to attract 50,000…
HOLDING COMPANY FOR INVESTMENT INTO AFRICA: MAURITIUS V THE REST?
For a long time Mauritius has been perceived as the country of choice to facilitate entry into Africa, but the fact remains that Mauritius has made a lot of changes recently, not all of them positive, and so it is worth examining whether that is still the case or not.…
MAURITIUS ON COURSE TO EXIT THE FATF “GREY LIST”
During the June 2021 Plenary held by the Financial Action Task Force (FATF), it was determined that Mauritius has substantially completed its Action Plan of implementing the necessary anti-money laundering and combating terrorism financing (AML/CFT) reforms ahead of the agreed deadline and has been commended for the progress it has…
SOUTH AFRICA EXCHANGE CONTROL – “LOOPING” STRUCTURES
SUBMISSION OF REPORTS TO THE FINANCIAL SURVEILLANCE DEPARTMENT OF THE SOUTH AFRICAN RESERVE BANK (SARB) RELATING TO THE ACQUISITION OF SOUTH AFRICAN ASSETS VIA OFFSHORE LOOP STRUCTURES. In the Exchange Control Circular 1/2021 of the SARB, it is noted that the full ‘loop structure’ restriction has been lifted to encourage…
CHINESE HOUSEHOLD WEALTH AND THE WEALTH CONNECT PROGRAMME – WHAT IT MEANS FOR BVI AND CAYMAN
A recent article written by Thomas Hale and Tabby Kinder, published in the Financial Times on 5th July 2021 brought to light some of the tentative steps taken by Chinese authorities at liberalization of their capital markets and the effects of the strengthening of the renminbi. (For the full article,…
WHAT YOU NEED TO KNOW ABOUT THE LIBOR TRANSITION
Many financial markets have relied on Interbank Offered Rates (IBORs), the basic rate of interest used in lending between banks, as a basis for a variety of financial transactions and decisions for decades. The London Interbank Offered Rate (LIBOR), the most widely used interest rate benchmark, is reported daily in…
CHANGES IN THE LAW REGULATING ACQUISITION/DISPOSITION OF PROPERTIES IN MAURITIUS BY FOREIGNERS
Mauritius real estate market has seen an increasing number of foreigners during the last decade who have acquired immovable property. The government of Mauritius implemented various schemes through which such properties can be acquired and the necessary legislative framework to regulate such activity by providing that any such acquisition requires…
CONTRIBUTION SOCIALE GÉNÉRALISÉE: MAURITIUS
As from 1 September 2020, the National Pension Fund has been abolished and replaced by the Contribution Sociale Généralisée (“CSG”). The CSG is an uncapped contribution and it aims to aid the low earning, including self-employed individuals as well as Small and Medium Enterprises (SMEs). Every participant and every employer…
CAYMAN ISLANDS ECONOMIC SUBSTANCE UPDATES AND FILING EXTENSION TO 31 JANUARY 2021
The ministry of financial services, Cayman Islands government have advised industry participants of the following important economic substance (“ES”) updates; ES Year 2019 will remain available on CAP until 31 January 2021. This extension only applies to this first year. The DITC Portal is open for registrations of outsource service…
South African Reserve Bank relaxes rules relating to “loops”
After many years of this being the ultimate no-no in terms of South African exchange control rules, the prohibition on “loop” structures is finally to be relaxed. Please note, however, that such an investment does not come without supervision as well as changes to the tax rules to prevent tax…
Greece introduces a new tax system for High-Net-Worth Individuals
Greece has recently seen fit to follow in Italy’s footsteps and introduce a new non-dom regime. The scheme was introduced in December 2019 and came into effect on the 1 January 2020. In order to join the scheme individuals will opt to pay a flat tax of €100 000 pa…
SOUTH AFRICA 2020 MEDIUM TERM BUDGET POLICY STATEMENT: HIGHLIGHTS
South Africa’s Minister of Finance delivered the 2020 Medium Term Budget Policy Statement on 28 October 2020. Key tax highlights from the budget policy statement include: No new tax proposals were introduced. The Government continues to project R5 billion (b) of tax increases in 2021/22. Government spending remains too high for the…
UNEXPECTED TAX RELIEF FOR EXPATRIATES “STUCK” IN SOUTH AFRICA
South African expatriates who were unable to leave South Africa on account of the lockdown will be relieved to learn that the requirements of the foreign employment exemption (Section10(1)(o)(ii)) will be relaxed. On 13 October 2020, National Treasury and SARS published their draft Response Document on the latest tax Bills, wherein…
MAURITIUS ON THE NEW EU LIST
On 7 May 2020, the European Commission announced the adoption of a new list of third countries which, according to the Commission, had strategic deficiencies in their anti-money laundering and counter terrorism financing (AML-CFT) regimes. On the very same day, the Commission announced that it had come up with a…
MAURITIUS FINANCE ACT 2020: KEY AMENDMENTS
The Finance (Miscellaneous Provisions) Bill 2020 (Bill) was introduced to the parliament on 7 July 2020. After being subject to parliamentary debates, The Finance (Miscellaneous Provisions) Act 2020 (“the Act”) was voted with amendments on 4 August 2020 and received the President’s assent on 7 August 2020. The Act provides…
Mauritius: An Attractive Lifestyle Destination, Opens Door To New Arrivals
The COVID-19 pandemic has not only been a health crisis, but has also affected society and the economy in most countries in varying degrees. The President of Mauritius assented to the Finance (Miscellaneous Provisions) Act 2020 (“Finance Act”) on 7 August 2020 which is geared towards a steady recovery of…
Mauritius Double Tax Treaty Update July 2020
Mauritius Zambia Treaty suspended The Zambian Cabinet has announced on the 22 June 2020 that the treaty with Mauritius has been terminated. However, they also announced the initiation of negotiations to negotiate a new agreement which will have share taxing rights and anti abuse clauses. In terms of the treaty…
FSC Mauritius – Regulatory relief on filing and reporting obligations
Further to the outbreak of the Covid-19 pandemic which has impacted on several local and international industries, and in order to alleviate regulatory burden on Licensees during such global crisis, the FSC has decided not to charge administrative penalties for late filing and reporting obligations due for below-mentioned periods. The…
Mauritius Budget 2020/21 Brief – Residence & Occupation permit holders
The budget 2020/21 has been presented by the Minister of Finance, Economic Planning and Development, Dr the Hon. Renganaden Padayachy, yesterday, 4 June 2020. The budget 2020/21 has been presented under exceptional circumstances and is considered to be momentous in the economical history of the country. It can be considered…
As the spread of Covid-19 continues…
As the spread of Covid-19 continues, we wanted to reassure you that the wellbeing of our clients and employees will be at the forefront of everything we do. We will of course continue to adhere strictly to Government advice in all the jurisdictions in which we operate, whilst remaining fully…
THE IMPACT COVID-19 ON TAX RESIDENCE STATUS
The OECD has taken stock of cross border tax issues that are likely to arise due to the current pandemic and has provided its guidance on how to best deal with those issues considering international tax treaty principles. We also investigate the UK’s statutory residence test (‘SRT’) which has been…
South African Budget 2020: Exchange Control Changes
For as long as we can remember exchange control has been part of every South African’s life. For years they were told that contravening these was a dire crime worthy of draconian punishment and perpetrating severe economic consequences on the South African economy. Now apparently, it is the controls themselves…
Mauritius E-Commerce tax holiday
E-commerce explained is a transaction whereby the buyer and the seller complete transactions online. In early 2019, the Prime Minister Pravind Jugnauth mentioned in his budget speech that the government is committed to fast track “the country’s move to an age of digitally enabled economic growth”. As such, the government…
Tax Treaty between Ghana and Mauritius
On 22 June 2018, Ghana’s parliament approved the ratification of the pending income and capital tax treaty with Mauritius which was signed on 11 March 2017, and which is the first of its kind between the two countries. Based on information released by the Mauritius Revenue Authority, we understand that…
Revised rules for foreign investments by South African Individuals
South African Reserve Bank “loop” structure – REVISED RULES FOR FOREIGN INVESTMENTS BY SOUTH AFRICAN INDIVIDUALS- EXCHANGE CONTROL CIRCULAR NO 18/2019 South African residents face restrictions known as exchange controls on transactions involving foreign currency. These are aimed both at protecting South Africa’s foreign currency reserves and controlling movements of…
Key Action Steps BVI Companies and Legal Entities Must take Before the End of 2019
On 9 October 2019, the BVI International Tax Authority (ITA) issued and released the long-awaited Rules on Economic Substance, a finalization of the draft guidelines and rules that were provided in late April. The rules will take effect on the date when the Beneficial Ownership Secure Search System (Amendment) (No.…
Corporate Tax Holidays in Mauritius
As part of the honourable Finance Minister’s annual budget speech, tax holidays provided to companies are announced. Click here to download the full article.
How to Distribute UK Residential Property from Offshore Companies
When distributing UK residential property from an offshore property holding company into the names of the beneficial owners or shareholders of the company, it is important to consider the various UK tax implications relevant to the distribution option. Generally, there are two distribution options to choose from: a distribution in…
Financially emigrating from South Africa? Let us help you
Financially emigrating from South Africa? Here’s why you should consider living in Mauritius… Following recent changes in the South African Revenue Service’s stance on foreign services tax exemption from offshore salaries, many people are unsure how this could affect them going forward. Let’s explore who could benefit from financial emigration…
EU proposal of substance requirements for zero tax territories
Proposed introduction of substance requirements for certain companies in the crown dependencies In response to pressure from the EU, Jersey, Guernsey and the Isle of Man have published consultations on the introduction of substance requirements for certain companies that are tax resident in those jurisdictions. Recently issued guidelines extend the…
Introduction of the new CGT charges for non-UK residents
Introduction of the new CGT charges for non-UK residents Further to recent consultations held and announced during the Autumn 2017 Budget speech, the UK Government will be introducing a new taxation of Capital gains tax (CGT) taxes on non-UK residents on disposals of any UK property (i.e. including commercial property)…
South African REIT rules change for new Stock Exchange
South African REIT’s rules to be amended by 2018 South African Income Tax Act. The draft Taxation Laws Amendment Bill of 2018 has brought in new rules to allow the 4 new exchanges licenced in South Africa to also qualify for REIT status. Previously, in order to qualify as a…
Forced Heirship and Succession Rules in Mauritius
Succession rules In most jurisdictions, one of the following two succession routes is adopted in respect to succession and inheritance law. The first route is where there is freedom of testation whereby residents of that country have the right to donate, in a will, their assets to whoever they wish.…
Mauritius Finance Bill 2018 – Critical Amendments to Global Business Sector
Further to the budgetary speech of 2017/2018 on 14 June 2018, the Finance (Miscellaneous Provision) Bill 2018 (“the Bill”) has been released for consultation. The bill incorporates the various measures announced by the Minister of Finance and this newsletter covers the key amendments to be brought to the Global Business…
Mauritius Introduces Citizenship Scheme
The 2018-19 budget presented by the prime minister included as one of its priorities, to enhance the economic growth in Mauritius, by attracting high net worth foreign investors and their families to the country. This budget now allows foreign nationals to benefit from enhanced existing schemes and also the introduction…
Mauritius Budget Brief 2018/2019
Recently the Mauritian Government unveiled it’s latest budget. Osiris has analysed the detail of the budget and how it can impact you. Please download the presentation here
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A New UK register of Beneficial Owners of Overseas Entities
In its commitment to making company and property ownership more transparent, the UK government, in 2016, announced its intention to introduce a public register of company ownership, recording information about who owns and controls UK companies. The proposed register will require overseas companies that own or buy property in the…
New rules for taxation of intra-group financing arrangements
On 30 June 2017, the Cyprus Tax Authorities (CTA) issued a Circular, guiding taxpayers on the implementation of new rules relating to intra-group financing activities in Cyprus from 1 July 2017. The Circular applies to intra-group financing activities where loans are granted by a company to related parties, financed by…
Introduction of 2 Tiered Profits Tax System
On 29 December 2017, the Hong Kong government sought to implement a two-tiered profits tax rates regime. Under the proposed regime, the profits tax rate for the first HKD 2 million (approximately US$250k) of profits of corporations will be reduced to 8.25%, while the standard profits tax rate of 16.5%…
Mauritius Double Tax Treaty Update
Mauritius had had a busy period recently with a number of treaties being negotiated and or signed but not yet in place. We highlight some of these here: The protocol to the treaty with Barbados has now been signed on the 12 December, 2017; Negotiations are ongoing with Zambia with…
Investing into UK property by non-residents
UK property has long been an investment of choice for non-UK residents looking for a stable and secure home for discretionary savings. This has historically also come with some significant tax advantages from the UK perspective. This status has been under attack for some time and many of the advantages…
South Africa 183 Day Exemption & CFC Update
South Africa 183 Day Exemption & CFC Update: In previous blogs, we had raised the prospect of changes to South Africa’s domestic Income Tax legislation. Of importance, was the proposed withdrawal of the tax exemption for South African tax residents who worked outside of South Africa for a sufficient period.…
Global Competitiveness Report 2017/2018: Mauritius in the Lead in Sub-Saharan Africa
Mauritius occupies the leading position in the Sub-Saharan African region for the fourth consecutive year – according to the Global Competitiveness Report 2017/2018 published by the World Economic Forum on 27th September 2017. Out of 137 countries, the country maintains its same ranking, at 45th, however with a slightly improved overall…
Mauritius and the Common Reporting Standard
Mauritius is a late adopter to the Common Reporting Standard (“CRS”). CRS evolved out of an OECD-led initiative currently supported by over 100 countries (“Participating Countries”). The purpose of CRS is to combat tax evasion. Participating Countries do this by the exchange of their tax residents’ tax information. Late adopter…
Recovery Continues: New Developments in the BVI Financial Services Industry
We are pleased to report that substantial progress is being made in the restoration of the financial and legal services available on Tortola. The backlog of past filings has been cleared. The BVI’s online incorporations system, VIRRGIN, is fully functioning. Regulatory submissions can now be completed electronically and on-island banking services…
Citizenship-by-Investment in Cyprus
The Republic of Cyprus has implemented various incentives in order to enhance and attract further foreign direct investments into the country. One of the schemes is the citizenship-by-investment program which grants Cypriot citizenship to those that invest EUR 2,000,000 or more in residential real estate, an investment amount which has…
UK’s Partnership with Mauritius Government to Further Position Mauritius as Fintech Hub for Africa
The high-level delegation led by Mr. Dev Manraj, the Financial Secretary is currently on mission in the United Kingdom met with representatives of the Foreign and Commonwealth Office (FCO) on 05 October 2017. Working sessions were held with Mr Tim Morris, Senior Trade Advisor for Africa at the Department Working…
Regulatory Sandbox Licence – More Opportunities For Business Investors In Mauritius
The Regulatory Sandbox Licence (RSL) is an initiative proceeding from the Mauritius 2016/2017 National Budget. The RSL regulation was broadcast under the Investment Promotion Act in October last year and the relevant guidelines were subsequently put in place. The RSL is a measure issued by the Board of Investment (BOI),…
Hurricane Irma: Osiris Reports “Staff Are Safe And BVI Office Is Operational”
We can now report that all our colleagues and their families are all safe and well following the recent historic Category 5 Hurricane Irma, which hit the BVI less than 2 weeks ago. Irma was followed by Cat. 4 Jose, which past north of Caribbean islands and Puerto Rico. We…
Hurricane Irma Update: Full Restoration of BVI Registry
As you are all aware the BVI has been severely impacted by Hurricane Irma as the hurricane travelled directly over the island. We would like to bring you up to date with the current state of affairs from an Osiris perspective. We have located most of our staff bar 3…
The Most Powerful Atlantic Ocean Storm In Recorded History
Miles Walton our Group Managing Director, who resides in Nanny Quay, Tortola, BVI, made contact with us in the early hours of this morning via satellite phone. The devastation from Hurricane Irma is dire, and at present Miles is unable to leave his house. As yet there has been no…
The Hong Kong Occupational Retirement Scheme Ordinance
The Occupational Retirement Schemes Ordinance (“ORSO”) came into force on 15 October 1993, and is the governing legislation for the regulation of voluntary occupational retirement schemes operating in or from Hong Kong. The ORSO aims to regulate the retirement schemes industry through a registration system to ensure that all voluntarily…
From Mara Delta to Grit and Association with Osiris
Mara Delta Property Holdings Ltd have announced in July 2017 its change of name to Grit Real Estate Income Group Limited, and the reason behind the name change is part of Grit’s strategy to expand its presence onto the African continent. Grit is seen as a low-risk investment company and…
Income Tax changes for South Africans Working Abroad
Proposed changes to the exemption on foreign-earned income, announced in the recent budget (on February 22 by former finance minister Pravin Gordhan at the 2017 National Budget) and how it will affect South Africans who work overseas, has become quite the controversial topic. Under the current rules, South Africans who…
Res Non-Dom Changes to Proceed in UK
In our article dated 1st May 2017 ‘Hold on Changes to UK Taxation of Res Non-Doms’, we noted that the proposed changes to the UK taxation of non-domiciliaries, which were to take effect from 6 April 2017, had recently been put on hold due to a shortage of Parliamentary time…
Relocation Services to Mauritius
Mauritius as a relocation destination offers the ideal package with its political stability, cultural diversity, low tax rates and sustained economic growth. Foreign nationals who wish to relocate to Mauritius may select from various options such as the Occupation Permit, the Residence Permit, Permanent Residence permit, Investor Permit and Retirement…
Mauritius Signs the Multilateral Convention to Implement Tax Treaty
On the 5th of July 2017 Mauritius signed the “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting”, at the Organisation for Economic Co-operation and Development (OECD) Headquarters in Paris as a commitment to the international movement to fight tax evasion and base erosion. The Multilateral…
Mauritius Means Business With Its New Budget
No longer just a tourist destination, this little island is flourishing. Through its 2017/18 Budget Speech, Mauritius has emphasised its commitment towards invigorating corporate growth, expanding social programmes, and stimulating the development of small businesses. With a projected growth rate of 4.1% expected during the next financial year, the Mauritian…
South Africa Demise of 183-Day Exemption. Should I Emigrate And If So, Where?
For years, South Africa has offered an exemption from tax in respect of South African residents who worked outside of South Africa for at least 183 days a year, including at least of one stint of 60 days. They would remain taxable in respect of any income earned in the…
Mauritius Budget Brief 2017-2018
Foreward The Honourable Pravind Kumar Jugnauth, Prime Minister, Minister of Home Affairs, External Communications and National Development Unit , Minister of Finance and Economic Development, delivered his Budget Speech for the fiscal year 2017/2018 on 8th June 2017. This year’s budget is set against the backdrop of ten key measures…
Mauritius Commits to Sign the Multilateral Convention
Mauritius, as a fully collaborative and responsible International Financial Centre (IFC) of substance, has always supported the implementation of best practices as set by leading globally recognised institutions. To this end, in June 2015, Mauritius signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, jointly developed by the…
Mauritius Business Facilitation Program
Ease of doing business is recognized the world over as a desirable attribute in trying to attract business into a jurisdiction. Over 10 years ago, the Business Facilitation Act 2006 (BFA) was introduced to improve the Mauritian business environment. Several measures were introduced such as the cut down on paperwork…
UK Property: Have They Killed the Golden Goose?
After investment in the UK property market sank to its lowest level in four years during the quarter after the Brexit vote, with the first quarter of 2017 well behind us, investment into UK real estate is not looking as gloomy as one would have anticipated and investment by non-UK…
Mauritius Property Purchase by Non-Citizens
With its attractive tax system and physical location, Mauritius has attracted its fair share of people attracted to relocate there for both the fiscal and physical attributes. In order to attract HNW’s to make it their home, Mauritius has offered several property investments, which lead to a right to live…
The OECD Common Reporting Standard
The Common Reporting Standard (“CRS”) was born out of an OECD-led initiative currently supported by over 100 countries (“Participating Countries”). CRS requires jurisdictions to obtain information from their financial institutions and automatically exchange that information with other jurisdictions on an annual basis. The purpose of CRS is to counter tax…
2017 Index of Economic Freedom (IEF) Reports Mauritius Retains Top Spot In Africa
Globally Mauritius ranks 21st as a “Mostly Free” economy by the 2017 Index of Economic Freedom (IEF 2017) but remains the top-scoring country in Africa. The IEF 2017 is based on 12 quantitative and qualitative factors, grouped into four broad categories and assesses 180 countries and is based on the…
Hold on Changes to UK Taxation of Res Non-Doms
The UK has a well-established Resident Non Domiciled (“Res Non Dom”) scheme, which allows those residents of the UK who are domiciled outside of the UK to elect to be taxed only on UK source income (remittance basis of taxation). Our article of September 2011, found here, sets out the then…
SEM Insight: Mauritius Stock Exchange Makes Significant Changes To Regulations
The Stock Exchange of Mauritius (SEM) has made a number of changes to its regulatory framework with a view to enhancing its international competitiveness. We have highlighted some of those below. 1. Fast Track Listing Process for International Issuers. With a view to assisting international issuers with secondary listings on…
Mauritius Double Tax Treaty Update April 2017
Mauritius already enjoys one of the better treaty networks in the world, regarding investment into Africa. This month has brought further news regarding the expansion of that network with the following news announced: 11th March 2017 announced that Ghana and Mauritius have signed a tax treaty in Port Louis. We…
Common Reporting Standard: BVI Extends Notification and Reporting Deadlines
On 24 March 2017 the British Virgin Islands government announced that the 2017 deadlines for notification and reporting obligations under the Common Reporting Standard (CRS) will be extended by two months. BVI Financial Institutions will have until 30 June 2017 to register with the BVI International Tax Authority (ITA) and…
CRS notification and reporting dates extended
CRS notification and first reporting deadlines have been extended by two months as announced in the Cayman Islands. The Cayman Islands have announced that they are extending the 2017 deadlines by 2 months, for Cayman Financial Institutions, to notify their status to the Cayman Islands Tax Information Authority (TIA) and file first…
Cayman Gears Up For Busy Business Friendly Legislative Agenda
It has been reported in the Cayman press that Wayne Panton’s ministry has prepared eleven bills, mostly relating to the regulatory framework surrounding new financial services vehicles, and to improve the business environment. Laws such as the Companies Management (Amendment) (No. 2) Bill, 2017; the Companies Amendment (No. 2) Bill,…
BVI Rolls Out Their Beneficial Ownership Secure Search System (BOSS)
Following on from the recent news in the Cayman Islands that they will be implementing a centralized platform of beneficial ownership, the BVI has also now revealed their New Beneficial Ownership Secured Search System. This is a new innovative technology platform called BOSS (Beneficial Ownership Secure Search System), which will…
Cayman Introduces A Centralised Beneficial Ownership Register
We can now report that Cayman has taken the decision to implement the concept of a centralised platform of beneficial ownership information by the 30 June 2017. The proposed beneficial ownership regime is welcomed as it is anticipated that this will bring an end to the intense debate that has…
Mara Delta Property Expansion: Hotel Industry
Delta Africa who recently changed its name to Mara Delta and positioned its head office in Grand Bay, Mauritius, and with whom we preserve strong business and partner relations keep proving themselves with their recent breakthrough in the hospitality sector. Mara Delta is an African property income fund with focus…
Mauritius – India DTAA Amendment: Mauritius remains preferred route for investments into India
On 10 May 2016, the DTAA (double taxation avoidance agreement) signed in 1982 between India and Mauritius was amended, which has potentially caused a major impact on relations between the two countries. At the time that India opened the doors of its economy to foreign investment, Mauritius became the preferred…
Mauritius Tax Holidays
The Mauritius Income Tax Act has recently been amended to grant Mauritius tax holidays to corporates licensed by the Financial Services Commission (FSC) and to individuals who are in employment with specific licensed corporations. These long-awaited measures have now been enacted through Regulations and we are pleased to provide you…
Amendments to Listing Rules on the Stock Exchange of Mauritius-International Issuers
In an attempt to make itself more of an attractive international platform for listed companies, the Stock Exchange of Mauritius (SEM) has recently made some amendments to its Listing Rules (dated December 2016), further to changes made to Chapter 15 for International Issuers. Some of the main amendments include: The…
The Stock Exchange of Mauritius – Dual Currency Trading Announced
The Stock Exchange of Mauritius (SEM) is today one of the leading Exchanges in Africa and a full-fledged member of the World Federation of Exchanges (WFE). The SEM is pursuing an internationalization strategy and gradually emerging as an attractive listing, trading and capital-raising platform offering international and multi-currency products. SEM’s…
Mauritius 2017 Budget – Emphasis On Tax Holidays To Encourage Development Of The Financial Sector
Mauritius has quietly gone about building its reputation as a safe, trusted and secured jurisdiction for financial services. In order to enhance the growth of the Mauritian economy and attract investors, emphasis has been placed on its competitive advantages which include a low and simple fiscal regime. This has now…
Mauritius GBC 2 Companies Now Allowed To Invest On Stock Exchange
The FSC of Mauritius has confirmed through its circular letter that as part of the Finance Act 2016 certain amendments have been enacted to allow companies with a GBC 2 category licence to invest in any securities listed on a securities exchange licensed under the Securities Act (the SEM or…
How Does The Common Reporting Standard (CRS) Impact On Mauritian Entities And Individual Investors?
Since the development and globalisation of financial markets, cross-border capital movements have been on the increase and same has rendered it rather easy for individuals and also entities to hold investments outside their own jurisdiction. By holding investments in several different jurisdictions, some may be doing so with the intention…
Cyprus Ethiopia Treaty Details: A New Scramble For Africa?
Cyprus Ethiopia Treaty details: A new scramble for Africa? The new double tax treaty between Cyprus and Ethiopia was signed on the 30 December, 2015. Details of that treaty have now become available. In general the treaty follows the OECD model treaty. In terms of the treaty the following withholding…
Hong Kong And China Sign The 4th Protocol To The Double Tax Treaty
Hong Kong and China signed a protocol to the double tax treaty between them in April 2015. That protocol has come into force with effect from 29 December 2015. The protocol amends the existing treaty as follows: Profits from the operation of ships or aircraft in the other country will…
Cayman Islands Limited Liability Companies Bill
The Cayman Islands recently published a bill for creating a new legal entity in the jurisdiction – the Cayman Limited Liability Company. It is expected to be enacted into law in January 2016. The investment fund industry had been calling for an entity like the LLC as it is thought…
Stock Exchange Of Mauritius (SEM) Market Review For 2015: “Record Year” For Capital Raising And Trading
The Stock Exchange of Mauritius has set itself the goal of positioning itself as a leading exchange in Africa (and internationally). To this end the SEM is becoming more and more an attractive option for listing, capital raising and trading for both local and international issuers. Latest figures released in…
St Lucia: Citizenship Programme Launched
The Citizen by Investment programme of St. Lucia was launched in October 2015, making St. Lucia the most recent entrant on this scene. This programme allows foreign investors to acquire citizenship under certain conditions. St. Lucia has started accepting applications as of 1 January 2016. This programme is a new…
Restricted Purpose Company (BVI)
BVI Business Companies are known for their ubiquitous flexibility across multiple jurisdictions. The Restricted Purpose Company (RPC) is a bit different. For those transacting, or doing business with a BVI company generally, it is quite well known that the BVI companies’ legislation gives wide corporate powers to corporate entities to…
Cape Town Convention Extended to Cayman Islands and UK
The Cape Town Convention is critically important for the financing of aircraft, and provides a system protecting the interests of financiers. With effect from 1 November 2015, the United Kingdom, including the Island of Guernsey, Cayman Islands and Gibraltar, has ratified the Cape Town Convention, being the Convention on International…
BVI Business Companies Act Amendments
The BVI Business Companies (Amendment) Act was gazetted on the 5 January 2016. The aim of the Act is to ensure that the BVI corporate vehicle is modern and well suited for current conditions and international standards. It is also intended to provide for greater flexibility and certainty for those…
Common Reporting Standard (“CRS”) – Important BVI Update
On 29 October 2014, the British Virgin Islands (“BVI”) was among 50 other jurisdictions which signed a Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (the “MCAA”) demonstrating its commitment to implement the CRS, an international regime developed by the OECD to facilitate and standardise the exchange…
BVI: Register of Directors To Be Filed
BVI Business Companies (Amendment) Act, 2015 It is shortly to be a requirement to file a register of directors. Therefore Osiris wishes to advise our BVI clients that the BVI Business Companies (Amendment) Act, 2015 was enacted in the House of Assembly on Monday 21 December, 2015. The Commission estimates…
Mauritius Revenue Authority Delay Implementation of CRS
On the 22nd December the MRA announced that the 1 January 2016 implementation of CRS has been deferred. No new date has been announced. Should you require further information then please contact: Dan Romburgh dan@cs00195.wpengine.com/ocs | www.osiristrust.com Telephone: +230 650 4030
How To Relocate To Mauritius: A Users Guide
Relocating to Mauritius is a big decision. It might have arrived because you have finally decided that the time has come for you to enjoy your place in the sun. More likely the Rand has depreciated more than you can bear, or you don’t feel like paying the resident non…
New Frontiers Ltd: A Mauritius GBC1 With UK REIT Status
Real Estate Investment Trusts have proved very popular world-wide as the way to structure listed investment holdings. The tax simplicity of having a flow through structure and only taxing the recipients of the Reit’s distributions has proved to be a success. Osiris was recently tasked by New Frontiers Ltd to set…
International Hotel Group Ltd lists on Luxembourg and Johannesburg Stock Exchange
We are proud to have been involved in the listing of the IHG Group on the Luxembourg and Johannesburg Stock Exchanges. IHG, which is a BVI company incorporated and managed by Osiris, listed on the JSE in October 2015. Osiris was retained to project manage the entire offshore side of…
South Africa Hong Kong Double Tax Treaty
On the 20th October 2015 the double tax treaty between South Africa and Hong Kong entered into force. The Treaty applies from 1 January 2016 for South Africa and 1 April 2016 for Hong Kong. Interesting points to note about the treaty are: Withholding taxes on dividends are reduced to…
Mauritius Morocco Double Tax Treaty Details Now Available
Details of the DTT signed between Mauritius and Morocco on the 25th November 2015 have now become available. The treaty is based on the UN model convention. Withholding rates are as follows: Dividends 10% unless the holding company holds at least 25% of the equity in which case a reduced…
Mauritius Investment Promotion Act Amended
The Mauritius Board of Investment has amended its requirements for holders of Occupation Permits, a very common form of entry into Mauritius as follows: The annual income for the self-employed category has been increased from MUR 600,000 to MUR 1,200,000 as from the third year of activity. The salary threshold…
Mauritius and Malta Double Tax Treaty Update
On the 23 April 2015 the double tax treaty between Mauritius and Malta entered into force. The announcement on the entry into force was made by in Mauritius on the 10th November 2015 by way of legal notice. Interesting points to note about the treaty are: No withholding taxes on…
Mauritius Investment Promotion and Protection Agreements
Mauritius is well known for extensive and continually expanding network of double taxation avoidance agreements (“DTAAs”) primarily focused on Africa, which has established its tax efficiency as an International Financial Centre. While ensuring tax efficiency of investors, Mauritius has also established Investment Promotion and Protections agreements (“IPPAs”), also known as…
Mauritius FSC Issues Code Of Conduct
The FSC has recently issued a Code of Conduct (the Code) under its Fair Market Conduct Programme. The Code will be effective from 1 January 2016. The principles under which all licensed entities are expected to operate list 9 guiding principles which are as follows: Skill care and diligence Business…
BVI FSC Announces Premium Service And Extended Hours
In an effort to improve service levels the BVI FSC has announced an expansion of service offerings with effect from November as follows: Premium Service A premium service is now available for time sensitive transactions for an extra fee. These transactions include the following: filings for sensitive, complex and…
Focus On The Mauritius Stock Exchange (SEM)
Focus on the Mauritius Stock Exchange (SEM) Mauritius is fortunate indeed to be home to the SEM. It is a well regulated stock exchange supporting a country with a vibrant local economy. With Mauritius now well recognised as the gateway to Africa, it will be interesting to see how the…
Cayman Islands Companies Makes Filing Changes and Offers Amnesty
The Companies (Amendment) Law 2015 has recently been passed by the Cayman Islands Legislative Assembly. The amendment will commence on Monday, 2 November 2015. The Act eases the financial penalties and timing requirements, for the late filing of changes in directors and officers. As from 2nd November 2015, Cayman companies…
Mauritius Signs Investment Promotion and Protection Agreement with UAE
September 2015 has seen the entry into force of a further Investment Promotion and Protection Act (IPPA). This was announced by the Mauritian Minister of Finance and Economic Development and the Zambian representative on the 20th September. IPPA are important ancillary treaties to the existing double tax treaty with the…
Mauritius Introduces Citizenship By Investment
For many years Mauritius has run a variety of investment schemes such as the IRS and RES schemes. These schemes provided that a non-citizen invested some $500 000 into various approved property schemes that the individual, their spouse, and dependents could obtain a right of residence in Mauritius. The Investment…
Mauritius Rated Highest Ranking Country In Africa By The Global Opportunity Index
The Global Opportunity Index is an index designed to examine the attractiveness of a country in attracting FDI. As such it looks at a composite group of factors including economic fundamentals, ease of doing business, regulatory quality, and rule of law. In the recently released survey Mauritius ranked 1st in…
South Africa Mauritius DTT Renegotiated
South Africa and Mauritius renegotiated their treaty in 2013. That treaty was ratified by the Mauritius Government in May 2015. The New DTA is to be effective from 1 January 2016. The most important aspect of this is that Mauritius Revenue Authority (MRA) and the South African Revenue Service (SARS)…
South Africa Mauritius MOU Redetermining Residence
South Africa and Mauritius renegotiated their treaty in 2013. That treaty was ratified by the Mauritius Government in May 2015. The New DTA is to be effective from 1 January 2016. Under the new treaty South Africa and Mauritius have entered into a MOU in terms of which they spell…