A Protocol amending the existing income tax treaty (1994) between Mauritius and the Kingdom of Eswatini (previously known as Swaziland) is expected to enter into force in January 2022, assuming ratification is completed.
The Protocol would revise the withholding tax rate on interest (increased to 7.5% from 5%) and would impose a withholding tax at a rate of 5% on management and professional fees.
Other changes in the Protocol would revise the permanent establishment article of the treaty, would add an article to facilitate the exchange of tax information, and would add an article to provide assistance regarding the collection of taxes.
Eswatini has not yet signed the OECD Multilateral Instrument (MLI). Mauritius is a signatory to the MLI, so that the MLI applies with regard to those tax treaties of which the treaty partner countries have also signed the MLI.
Read a February 2021 report [PDF 143 KB] prepared by the KPMG member firm in Mauritius
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