The Mauritius Revenue Authority (MRA) said last week that the protocol amending the Mauritius-India Double Taxation Avoidance Agreement (DTAA) to comply with the base erosion and profit shifting minimum standards, is yet to be ratified.
The clarification comes days after the Indian income tax authorities said in a post on social media platform X that the protocol is yet to be ratified and notified under Section 90 of the Income Tax Act.
The MRA said the protocol will amend the DTAA once it is ratified and notified by both countries.
“The protocol shall come into force on the date of the later of these notifications. Prior to the ratification of the protocol, stakeholders will be provided with clarificatory information on the amendments being brought to the Mauritius-India DTAA,” the MRA said in a communique released on April 17.
India and Mauritius signed an amendment to the DTAA on March 7 and included a principal purpose test in the pact in order to ensure that treaty benefits are granted only for transactions with a bona fide purpose.
The application of the PPT to grandfathered investments remains ambiguous and requires clarity from tax authorities.