06 December 2013

India: Clause to avoid Mauritius treaty abuse

Indian and Mauritius authorities engaged in renegotiating the tax treaty between the two countries have agreed to include a "limitation of benefit" (LOB) clause to prevent any misuse of the beneficial provisions of the tax treaty. The insertion of the LOB clause—an anti-abuse provision which limits the ability of third country residents to obtain benefits under a tax treaty between two other countries— had been a long-standing demand from India.

No comments: