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 double taxation. We understand that the treaty also complies with the OECD/G20 Base Erosion and Profit Shifting (BEPS) recommendations. We will provide further information as the text becomes available.
- The DTT between Estonia and Mauritius was signed on the 19th February 2021 and details are now available. The treaty generally follows the OECD Model treaty. Maximum rates of withholding tax are as follows:
- 7% on dividends generally, but 0% if the beneficial owner is a company;
- 7% on interest generally, but 0% if the beneficial owner is a company; and
- 5% on royalties generally, but 0% if the beneficial owner is a company.
There are a number of deviations from the OECD model but the treaty is interesting as Mauritius has historically been more focussed on Africa, and this may be the beginning of a new trend towards other parts of the world.