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Mauritius - India Tax Treaty (as amended by 2016 protocol) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 18

Governmental Functions

(1) Remuneration, other than pension, paid by the Government of a Contracting State to an individual who is a national of that State in respect of services rendered to that State, shall be taxable only in that State.

(2) Any pension paid by the Government of a Contracting State to an individual who is a national of that State, shall be taxable only in that Contracting State.

(3) The provisions of paragraphs 1 and 2 of this Article shall not apply to remuneration and pensions in respect of services rendered in connection with any business carried on by the Government of either of the Contracting States for the purpose of profit.

(4) The provisions of paragraph 1 of this Article shall likewise apply in respect of remuneration paid under a development assistance programme of a Contracting State, out of funds applied by that State, to a specialist or volunteer seconded to the other Contracting State with the consent of that other State.

(5) For the purposes of this Article, the term 'Government' shall include any State Government or local statutory authority of either Contracting State and, in particular, the Reserve Bank of India and the Bank of Mauritius.