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Mauritius Publishes Synthesized Text of Tax Treaties with Cyprus, Egypt, and France as Impacted by the BEPS MLI — Orbitax Tax News & Alerts

The Mauritius Revenue Authority (MRA) has published the synthesized texts of the tax treaties with Cyprus, Egypt, and France as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaty and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2000 Mauritius-Cyprus tax treaty:

  • In Mauritius
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 July 2020;
    • with respect to all other taxes levied by Mauritius, for taxes levied with respect to taxable periods beginning on or after 1 November 2020;
  • In Cyprus:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the tax period beginning on or after 1 January 2021;
    • with respect to all other taxes levied by Cyprus, for taxes levied with respect to taxable periods beginning on or after 1 November 2020.

The MLI applies for the 2012 Mauritius-Egypt tax treaty:

  • In Mauritius
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 July 2021;
    • with respect to all other taxes levied by Mauritius, for taxes levied with respect to taxable periods beginning on or after 1 July 2021;
  • In Egypt:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the tax period beginning on or after 1 January 2021;
    • with respect to all other taxes levied by Egypt, for taxes levied with respect to taxable periods beginning on or after 1 July 2021.

The MLI applies for the 1980 Mauritius-France tax treaty:

  • In Mauritius
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 July 2020;
    • with respect to all other taxes levied by Mauritius, for taxes levied with respect to taxable periods beginning on or after 1 August 2020;
  • In France:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the tax period beginning on or after 1 January 2021;
    • with respect to all other taxes levied by France, for taxes levied with respect to taxable periods beginning on or after 1 August 2020.

Notwithstanding the above, the provisions of Part VI (Arbitration) of the MLI have effect with respect to the treaty for cases presented to the competent authority of a Contracting State on or after 1 February 2020, and for cases presented prior to that date to the extent agreed by the competent authorities.

Click the following link for the MRA's International Taxation webpage, which includes the MLI synthesized texts.