India, Mauritius sign protocol to amend tax treaty

New Delhi, April 11

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India and Mauritius have signed a protocol to amend the double taxation avoidance agreement (DTAA), which included a principal purpose test (PPT) to decide whether a foreign investor is eligible to claim treaty benefits.

Tax experts said a new article has been added to the protocol “Article 27B Entitlement to Benefits”. The amended protocol was signed on March 7 and made public now. The introduction of the PPT aims to curtail tax avoidance by ensuring that treaty benefits are only granted for transactions with a bona fide purpose. Nangia Andersen India Chairman Rakesh Nangia said the amendment represents a move by India to align with global efforts against treaty abuse, particularly under the BEPS Action 6 framework.