The MLI is designed to implement tax treaty related measures to prevent Base Erosion and Profit Shifting(BEPS).The purpose of this alert is to provide an update on the position of Mauritius with respect to the MLI.
The MLI is an agreement negotiated under Action 15 of the OECD/G20 BEPS Projectwhich allows the amendment of Double Taxation Avoidance Agreements (DTAAs) without the necessity to conduct additional negotiations between two countries.
The measures under the MLI include, inter-alia, anti-treaty abuse rules such as the Principal Purpose Test (PPT) and limitation of benefit clause, alongside a new preamble reinforcing anti-treaty abuse rules, permanent establishment rules, arbitration rules, modernization of Mutual Agreement Procedures and transfer pricing articles in tax treaties.
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