Mauritius has completed its domestic ratification of the protocol amending the Mauritius–India Double Taxation Avoidance Agreement, introducing strengthened anti-abuse provisions and a Principal Purpose Test (“PPT”).
While the protocol is not yet in force, its implementation will have implications for groups with existing Mauritius–India investment structures and cross-border arrangements.
This update outlines the key amendments introduced by the protocol, including changes to the treaty preamble and the introduction of the PPT, as well as existing guidance on its prospective application and the treatment of grandfathered investments. It also considers the potential implications for the commercial rationale, substance, governance, and documentation supporting Mauritius–India structures.
