Goût de France / Good France : un dîner pour célébrer la gastronomie autour du monde (19 mars 2015)

Le jeudi 19 mars 2015, 1500 dîners seront proposés dans les restaurants et ambassades de 150 pays répartis sur les 5 continents, afin de célébrer la gastronomie française en invitant le public à partager un « dîner français ». Dans chaque restaurant participant, l’évènement rendra hommage à une cuisine vivante, ouverte et innovante, tout en restant fidèle à ses valeurs : partage, plaisir, respect du bien-manger et de la planète.

Goût de / Good France est organisé à l’initiative d’Alain Ducasse et du ministère des Affaires étrangères et du Développement international.

Laurent Fabius a déclaré lors de la présentation du projet : « Le patrimoine de la France, c’est la cuisine, ce sont les vins, (…) le repas à la française est inscrit depuis 2010 au Patrimoine mondial de l’UNESCO, mais c’est un patrimoine qu’il ne faut pas seulement contempler ou glorifier ou savourer, c’est un patrimoine qu’il faut faire fructifier et mettre en valeur ».

Pour Alain Ducasse : « La cuisine française est l’interprète d’une cuisine qui a évolué vers la légèreté dans l’harmonie avec son environnement (…) le point commun c’est la générosité, le partage, l’amour du beau et du bon, il s’agira d’une parenthèse enchantée, l’occasion de fêter la cuisine française partout dans le Monde ». 

S’inspirant d’Auguste Escoffier qui initiait en 1912 « les Dîners d’Épicure » — le même menu, le même jour, dans plusieurs villes du monde et pour le plus grand nombre de convives — Goût de / Good France reprend cette belle idée avec la volonté d’associer des restaurants aux quatre coins du monde.

Les chefs proposeront dans leurs établissements un menu « à la française » avec un apéritif de tradition française, une entrée froide, une entrée chaude, un poisson ou crustacé, une viande ou volaille, un fromage français (ou une sélection), un dessert au chocolat, des vins et un digestif français, tout en restant libres de mettre en valeur leur propre tradition/culture culinaire.

Une cuisine accessible à tous, du bistrot aux tables d’exception, réalisée à partir de produits frais de saison et issus du terroir local, avec moins de graisses, de sucres, de sel et de protéines. 

Le prix du menu est à la discrétion du restaurant et chacun est encouragé à reverser 5% des ventes à une ONG locale oeuvrant pour le respect de la santé et de l’environnement.

Un voyage gastronomique

C’est une véritable invitation au voyage que la France adresse au monde : réunir plus de 1500 chefs des 5 continents qui s’approprieront les atouts de la gastronomie française pour exprimer leur talent à travers 1500 menus. 

Dès le 21 janvier 2015, l’ensemble des restaurants participants est présenté sur le site goodfrance.com. 

Sur les 5 continents, chacun pourra identifier les participants situés dans sa ville / son pays et réserver en contactant directement le restaurant de son choix.

De nombreux chefs ont d’ores et déjà intégré leur menu sur le site internet permettant à tous d’imaginer le dîner qu’ils savoureront le 19 mars.

Un comité international de chefs

Les restaurants du monde entier - de la haute cuisine à la cuisine de bistrot - ont été invités à candidater sur le site www.goodfrance.com, en proposant un menu valorisant la tradition culinaire française.

Un comité international de chefs, présidé par Alain Ducasse, a validé la liste des chefs participants, parmi eux Paul Bocuse (France), Raymond Blanc (Royaume-Uni), Thomas Keller (Etats-Unis), Kiyomi Mikuni (Japon), Paul Pairet (Chine), Joël Robuchon (France), Nadia Santini (Italie), Guy Savoy (France)…

Une occasion unique de savourer et faire savourer la France

Ce voyage gastronomique illustre parfaitement deux éléments importants de la culture française : la mise en avant des terroirs et l’ouverture sur le monde.

L’occasion de partager avec le plus grand nombre des valeurs qui sont chères aux Français et qu’il faut continuer à défendre avec ardeur : la convivialité, le respect de la planète et des ressources qu’elle porte. Et très important : le plaisir.

Plus que jamais, la gastronomie est un élément phare de la France et de sa culture. 60 % des touristes visitant l’hexagone en font une véritable motivation.

Au delà des restaurants participants, les ambassades françaises relaieront également l’opération en organisant de leur côté des dîners dans les résidences des ambassadeurs. « Ce sera la parfaite illustration du classement au patrimoine culturel de l’humanité par l’Unesco du repas gastronomique des Français », a déclaré Laurent Fabius. « C’est aussi un moyen de rendre plus attractive la destination France » précise de son côté Alain Ducasse.

Ile Maurice restaurants/chefs participants:

La Rose Des Vents, Labourdonnais Caudan Waterfront - Port Louis
Chef: Nizam Peeroo 
Le Château De Bel Ombre, Domaine de Bel Ombre, Chef: Ravi Kanhye 
Le Courtyard Restaurant, Port Louis, Chef: Mootoosamy Vasoo Alankalee 
Le Whatever Tamarin Mauritius, Chef: Alain Guinaudeau 
Beach Rouge LUX Belle Mare, Belle Mare, Chef: Vincent Rodier 
Château Mon Désir Maritim – Balaclava, Chef: Eric Poutot, 
La Clef des Champs Floréal , Chef : Jacqueline Dalais,
La Goélette , Royal Palm - Grand Baie, Chef: Michel De Matteis


Château Mon Désir
Chef : Poutot Eric

Menu

Entrée froide :

Carpaccio de coquilles St Jacques marinées avec une vinaigrette à l’huile d'olive AOC de Menton parfumée avec son jus de coriandre et citron, croquettes de saumon et son caviar de poisson. 

Entrée chaude :

Crème de Polenta à la truffe d’hiver servie avec son oeuf de caille frit parsemé de dés de foie gras. 

Soupe 

‘Valérie Giscard d’Estaing’ de Paul Bocuse 

Poisson ou crustacé :

Bar de la Méditerranée flambé au fenouil servi avec une ratatouille provençale accompagné de sa cassolette de moules marinière 

Viande ou volaille :

Tournedos de filet de bœuf ‘Rossini’ servi avec pommes de terre façon Venassienne, endives caramélisées et ses jeunes carottes fondantes, sauce Pommerol 

Fromage :

Assortiment de 5 sortes de fromage français affinés par un maître fromager servis avec des tranches de pain aux fruits confits 

Dessert :

Soufflé au chocolat ‘Callebaut’ servi avec sa crème glacée à la vanille faite maison 

Prix du menu :
Rs 4700

La Clef des Champs
Chef : Jacqueline Dalais

Menu

Entrée froide :

Calisson fondantde langouste 

Entrée chaude :

Cappuccino d'oursins de nos mers, Tuille de pain à l'ancienne grillée aux herbes 

Poisson ou crustacé :

Pavé de saumon aux noix de St Jacques & girolles, Sauce crémée 

Viande ou volaille :

Epaule d'agneau confite, tranches d'aubergines et artichauts frais 

Fromage :

Bleu du Queyras, Pyrénées Brobis (Fromage au lait de Brebis), Beaufort Réserve (au lait de vache), Brie de Melun, Vieux conté Extra 

Dessert :

Succès Praliné 

Prix du menu :
Rs 3000 TTC

La Goelette
Chef : Michel De Matteis

Menu

Entrée froide :

Marbré de foie gras de canard au thon Albacore et fruits exotiques 

Entrée chaude :

Mousseline de crevettes tigrées, biscuit de cocotier 

Poisson ou crustacé :

Petit salé de la mer de la créole 

Viande ou volaille :

Croquant d’agneau aux céréales, endives caramélisées aux épices 

Fromage :

Sélection de notre maitre fromager Hervé Mons 

Dessert :

Dome vanille passion, sorbet noix de coco 

Prix du menu :
Rs 4200


La Rose Des Vents
Chef : Nizam Peeroo

Menu

Entrée froide :

Rouelle de Coeur de Palmier Pochée, Tartare de chair de crabe FaiFai, Sauce emulsionnée au Combava 

Entrée chaude :

Poêlé de Foie gras de Canard de Terracine au suc de mangue 

Poisson ou crustacé :

Filet de Vieille Rouge cuit au four accompagé de son Maki de pomme d'amour, Filament de piment craquant de pois mange tout, beurre blanc parfumé au feuille de carri poulée 

Viande ou volaille :

Longe de cerf cuit en basse température, mousseline d'Arouille, étuvé de brède malabar et son jus de cuisson relevé au baie rose 

Fromage :

Rôti de Camembert cerneaux de noix, Miel organique Niaouli 

Dessert :

Sphère au chocolat, chiboust de banane figue caramélisée au sucre de muscovado et flambé an rhum brun de chamarel 

Prix du menu :
Rs 1800 (Inc.Vat) (45 Euro)


Le Château De Bel Ombre
Chef : Ravi Kanhye

Menu

Entrée froide :

Cuisse de canard en rillettes, copeaux de magret fumée et salade d’asperges croquantes 

Entrée chaude :

Bisque de langouste et sa mousse au caviar 

Poisson ou crustacé :

Filet de saumon mi-cuit au sel noir, sauce champagne et jeunes légumes confits à la truffe 

Viande ou volaille :

Tournedos de « Bœuf Rossini » et sauce madère 

Fromage :

Assiette de fromages affiné ; Reblochon fermier, Tomme de Savoie et Vieux comté 

Dessert :

Mille-feuille au chocolat 

Prix du menu :
Rs 3500

Le Courtyard Restaurant
Chef : Mootoosamy Vasoo Alankalee

Menu

Entrée froide :

Cœur de Palmier frais en salade, dés de thon Albacore Mesclun et sa vinaigrette aux agrumes 

Entrée chaude :

Escalopés de foie gras poêlé, Crème de Cassis réduite, salsa d’avocats 

Poisson ou crustacé :

Noix de St Jacques poêlé et scampi grillé sur un lit forestier Emulsion de jus de crustacés 

Viande ou volaille :

Magret de canard poêlé à la fleur de sel ou Carrée d’agneau rôti Panachés de pommes de terre sautées Julienne de mangetout 

Fromage :

La ronde de la vachère (Camembert AOP, Crottin de Chavignol, Bleu d'Auvergne) 

Dessert :

Coulant au chocolat noir, Crème glacé maison au miel et gingembre 

Prix du menu :
Rs 2150

Le Whatever
Chef : Alain Guinaudeau

Menu

Entrée froide :

Enroulé de feuille de calamar au crabe, palmiste et combawa, bohémienne glacée de jeunes légumes, tuile craquante à l'encre de seiche 

Entrée chaude :

Oeuf parfait, mousseline de giraumon, chantilly au lard boucané et croustillant parmesan-toucmaria 

Poisson ou crustacé :

Pot au feu de vieille laboue en nage de crustacés à la citronelle et légumes fondants 

Viande ou volaille :

Roulade de suprêmes de volaille au foie gras et badames, jus réduit, espuma d'arouille et brède tom pouce laqué 

Fromage :

Tranche crémeuse de brie de Meaux, mesclun bio d'ici 

Dessert :

Tarte fine chocolat guayaquil, sorbet aux goyaves et épices, zéphyr coco 

Prix du menu :
4750 Rs avec champagne, vins et digestif français inclus

LUX Belle Mare
Chef : Vincent Rodier

Menu

Entrée froide :

Gravlax de thon jaune, coeur de palmier croquant, jaune d'oeuf de caille poché au vieux rhum de Chamarel, milkshake d'avocat 

Entrée chaude :

Consommé clair de langouste infusé aux feuilles de Kaffir, ravioles de langouste, perle de bisque au gingembre 

Poisson ou crustacé :

Sacré-chien en croute de gateau piment, émulsion de sauce rougaille, barigoule de chou-chou et chorizo 

Viande ou volaille :

Carré d'agneau façon Rogan Josh gratiné aux fruits moelleux, samoussa d'épaule confite au citron, condiment d'ail 

Fromage :

Gaperon de mes terres affiné par la maison Mons, pétale de litchi confit 

Dessert :

Truffle en duo, fleur de cacao et thé au jasmin 

Prix du menu :

Rs 2000

Goût de France / Good France Menu for Mauritius

Mauritius: Launch of a new Fund - NJ Global Opportunities Fund

NJ Group, a leading player in the Indian financial services industry has launched a new Fund "NJ Global Opportunities Fund" on 21 January 2015 at 3.00 pm at Labourdonnais Waterfront Hotel, Port Louis, in the presence of The Honourable Pravin Kumar Jugnauth - Minister of Technology, Communication and Innovation, The Honourable Sudarshan Bhadain - Minister of Financial Services, Good Governance and Institutional Reforms and Mr Nishith Desai, the Founder and Managing Partner of Nishith Desai Associates.

Cim Global Business which is part of Cim Group is acting as the Management company and has been instrumental in setting up NJ Group GBL1 companies & its subsidiaries in Mauritius.

Goût de France / Good France: a dinner to celebrate gastronomy worldwide (March 19, 2015)

On Thursday, 19 March 2015, in 150 countries around the world, restaurants and embassies will offer 1500 dinners to celebrate France’s gastronomy by inviting the public to share a “French dinner”. In each participating restaurant, the event will pay tribute to a vibrant, open and innovative cuisine, while remaining true to its values of sharing, pleasure, respect for good food and for the planet.

The Goût de France/Good France project is being organized on the initiative of Alain Ducasse and the Ministry of Foreign Affairs and International Development.

During the project’s presentation, Laurent Fabius said: “France’s heritage is its cuisine, its wines, (...). The Gastronomic meal of the French has been on the UNESCO World Heritage list since 2010, but it is a heritage that should not simply be contemplated, glorified and savoured; it is a heritage that should be built upon and showcased.”

In the words of Alain Ducasse: “French cuisine is the interpreter of a cuisine that has evolved towards lightness in harmony with its environment... The common point of this event is generosity, sharing and the love of what is beautiful and tastes good. It will be a delightful interlude and an opportunity to celebrate French cuisine worldwide.”

Inspired by Auguste Escoffier, who launched the “Dîners d’Épicure” (Epicurean Dinners) initiative – the same menu, the same day, in several world cities and aimed at as many diners as possible – in 1912, Goût de France/Good France reproduces that beautiful idea with the desire to involve restaurants all around the world.

Each chef will offer a “French-style” menu in their restaurant with a traditional French aperitif, a cold starter, a hot starter, fish or shellfish, meat or poultry, a French cheese (or cheeseboard), a chocolate dessert, French wines and digestifs, while remaining free to highlight their own culinary traditions and cultures.

The cuisine will be accessible to all, from bistros to exceptional restaurants, and based on fresh, seasonal and local products with lower levels of fat, sugar, salt and protein.

The menu’s price is at the restaurant’s discretion, and they are all encouraged to donate 5% of proceeds to a local NGO promoting health and the environment.

A gastronomic journey

France is sending the world a real invitation to journey, bringing together more than 1500 chefs from around the world who will take advantage of French gastronomy’s assets to express their talent and expertise through 1500 menus.

On 21 January 2015, all participating restaurants will be presented on the goodfrance.com website.

It will be possible for everyone worldwide to identify participating restaurants in their city/country and to book directly at the restaurant of their choice.

Many chefs have already posted their menu on the Good France website, to enable everyone to imagine the dinner they will savour on 19 March.

An international committee of chefs

Eateries around the world – from haute cuisine restaurants to bistros – are currently encouraged to apply on the goodfrance.com website, proposing a menu that showcases France’s culinary traditions.

An international committee of chefs, chaired by Alain Ducasse, has approved the list of participating chefs, including Paul Bocuse (France), Raymond Blanc (United Kingdom), Thomas Keller (United States), Kiyomi Mikuni (Japan), Paul Pairet (China), Joël Robuchon (France), Nadia Santini (Italy) and Guy Savoy (France).

A unique opportunity to enjoy and share the taste of France

This gastronomic journey is a perfect illustration of two important aspects of French culture: promoting local specialities and openness to the outside world.

It will be an opportunity to share values that are dear to the French people – and which we need to continue defending ardently – with as many people as possible: conviviality and respect for our planet and its resources. And, most importantly, pleasure.

Now, more than ever, gastronomy is a leading aspect of France and its culture. It is a genuine pull factor for 60% of tourists visiting the country.

In addition to the participating restaurants, French embassies will also be taking part in the event, organizing dinners in the residences of Ambassadors. “This will be a perfect illustration of UNESCO’s World Heritage listing of the Gastronomic Meal of the French”, said Laurent Fabius. “It is also a way to make France more attractive as a destination”, added Alain Ducasse.

Participating restaurants/chefs in Mauritius

La Rose Des Vents, Labourdonnais Caudan Waterfront - Port Louis, Chef: Nizam Peeroo 
Le Château De Bel Ombre, Domaine de Bel Ombre, Chef: Ravi Kanhye 
Le Courtyard Restaurant, Port Louis, Chef: Mootoosamy Vasoo Alankalee 
Le Whatever Tamarin Mauritius, Chef: Alain Guinaudeau 
Beach Rouge LUX Belle Mare, Belle Mare, Chef: Vincent Rodier 
Château Mon Désir Maritim – Balaclava, Chef: Eric Poutot, 
La Clef des Champs Floréal , Chef : Jacqueline Dalais,
La Goélette , Royal Palm - Grand Baie, Chef: Michel De Matteis

UK: BoE bows to pressure to reveal barrister’s fees for forex inquiry report

The Bank of England has bowed to pressure from MPs to reveal how much taxpayer money it spent on instructing a top barrister to investigate whether Bank officials knew about alleged manipulation of the foreign exchange market.

FT

Becoming Irresistible: A New Model for Employee Engagement

The employee-work contract has changed, compelling business leaders to build organizations that engage employees as sensitive, passionate, creative contributors. Two years of research and discussions with hundreds of companies conducted by Bersin by Deloitte suggest five major elements and underlying strategies that work together to make organizations “irresistible" to employees

Becoming Irresistible: A New Model for Employee Engagement [Deloitte Review, Issue 16, January 2015]

Open Data Barometer highlights the need for governments to increase open data efforts

The second edition of our Open Data Barometer, released today, shows that hard work lies ahead if Open Government Data (OGD) is to live up to its full potential and deliver truly transformative impacts. Governments worldwide have acknowledged the potential of OGD to reduce corruption, increase transparency, and improve government services, yet over 90% of the 86 countries surveyed in this edition of the Barometer do not publish key datasets in open formats. Despite pledges by the G7 countries to boost transparency by making government data “open by default”, almost half of the G7 countries are still not publishing the key datasets they promised to release in 2013, while fewer than 8% of the countries surveyed worldwide publish datasets on government budgets and spending, public sector contracts, and company ownership in open formats and under open licenses.

The 2014-15 edition of the Open Data Barometer examines open data readiness, implementation, and impact across 86 countries, and provides a country ranking based on scores in each of these three categories. The findings from the newly released report point to a growing divide between those countries able to establish and sustain open data programmes, and those countries where open data activities have stalled, moved backwards or not yet begun. The UK once again earned the top spot in the Barometer’s global rankings this year, followed by the US, Sweden, France and New Zealand. Among developing nations, Indonesia, Nigeria and Brazil all were praised for strong progress.

Commenting on the report’s findings, Sir Tim Berners-Lee, Web inventor and founder of the Web Foundation, noted that “governments continue to shy away from publishing the very data that can be used to enhance accountability and trust” and highlighted the power of open data “to put power in the hands of citizens”.

As data becomes ever more important in shaping policy debates, the importance of citizens having effective access to data grows; yet without dedicated efforts, the unfolding “data revolution” risks leaving many behind. In order to increase the availability of OGD and amplify the power of citizens to use this data effectively, the report highlights certain factors common among successful open data initiatives:

• High-level political commitment. Implementing the requirement to disclose and regularly update OGD in law or policy as part of a wider right to information ensures that data is available, open and accurate. At the same time, governments must work to ensure that strong privacy protections are in place and respected.
• Consistent and sustained support for both national and city-level open data programmes. This support must be sustained beyond initial open data efforts.
• Enhance the ability of government, civil society and entrepreneurs to understand and use data effectively. Resources dedicated to building the capacity of data users both inside and outside the government is critical to maintaining a supply-demand data balance and an increase in this understanding and ability can be accomplished through trainings and adapting open data tools to local needs.

Download the full report

Transparency: Cracking the shells

Under the new rules, countries will have to set up central registers of companies’ “beneficial” owners—that is, the real people behind firms or the ownership structures that sit atop them.

The Economist

Vistra Group launches new brand identity

Vistra Group, one of the world’s leading corporate service providers of international incorporations, trust, fiduciary and fund administration services, today announced the launch of a refreshed brand that unites Vistra and OIL, the group’s main internationally operated brands under the same family. The new brand heralds an exciting new chapter in the Group’s strategic development and culminates four years of successful integration and formalises the connections that all the member companies share.

Under the new brand, Vistra and OIL remain as distinct and complementary brands operating separately but with a strong linkage between them symbolising the integrated way in which the group operates. Additional brands joining the Group as a result of various acquisitions will also follow the new brand hierarchy depending on their market position.

• Following the acquisition of Trinity Corporate Services, the leading corporate services provider in Central and Eastern Europe, in November last year, Trinity becomes integrated with Vistra under this new brand.
• TAKA will continue to operate under its current name but be brought under the new brand identity.
• NovaSage, which is also part of the Vistra Group, will continue to operate under its own brand identity and will be identified as “a Vistra Group Company”.

Martin Crawford, Chief Executive Officer of Vistra Group, said, “Coming together at this time helps us to be more than the sum of our parts – for our clients, our people and our investors. Having Vistra, OIL, TAKA and NovaSage under a single Group name reinforces the linkages between our businesses and demonstrates to the industry that Vistra Group is united by one story. Vistra Group now provides a better connectivity between Asia, Europe and the rest of the world. In addition, the Group’s wide access to deep specialist knowledge will help us deliver expert solutions globally and swiftly.”

The rebrand comes at a time when the industry is facing an evolving environment where doing business across international borders provides great opportunities, but at the cost of complexity.

While the fundamental role of corporate services, trust, fiduciary and fund administration services in facilitating the global financial supply chain, including international trade, capital efficiency and asset management is being better recognised, recent regulatory changes have also encouraged the industry to embrace tighter regulations, more transparency and a higher degree of professionalism.

Under such context, Vistra Group predicts that industry consolidation among service providers is inevitable, and Vistra Group is well positioned to cement its position as one of the “Big Four”  among global corporate service providers. Rebranding now presents an excellent opportunity to showcase the depth, breadth and power of the combined group as clients demonstrate a real flight to quality.

“The Group’s combined synergies in cross industry knowledge sharing and robust compliance structure gives us the ability to flex up our offer to meet the ever increasing demands of doing business across international borders,” Mr. Crawford added, “With a globally recognised and stronger B2B brand, our scale in the industry creates a distinct competitive advantage for us. Through integration, we can now benefit from seamless end-to-end services and the greater global reach, and hence provide an even more competitive offering to clients. Our Group versatility from execution to tailored solutions sets us apart. Under the Vistra Group brand, we are confident that each of our group companies will thrive and together, will deliver consistent growth.” 

IAASB Issues Final Standards to Improve Auditor's Report

The International Auditing and Assurance Standards Board® (IAASB®) today released its new and revised Auditor Reporting standards, designed to significantly enhance auditor’s reports for investors and other users of financial statements.

"These changes will reinvigorate the audit, as auditors substantively change their behavior and how they communicate about their work," explained Prof. Arnold Schilder, IAASB Chairman. “Informed by extensive research and global outreach to investors, regulators, audit oversight bodies, national standard setters, auditors, preparers of financial statements, audit committee members, and others, the final International Standards on Auditing (ISAs) represent a momentous—and unprecedented—first step. Now, we must study, promote, and plan for the effective implementation of the new and revised standards.”

"The IAASB has responded to calls from investors and others that it is in the public interest for an auditor to provide greater transparency about the audit that was performed," added Dan Montgomery, former IAASB Deputy Chair and Chair of the Auditor Reporting project. "Increasing the communicative value of the auditor’s report is critical to the perceived value of the financial statement audit."

The most notable enhancement is the new requirement for auditors of listed entities’ financial statements to communicate "Key Audit Matters"—those matters that the auditor views as most significant, with an explanation of how they were addressed in the audit. The IAASB has also taken steps to increase the auditor’s focus on going concern matters, including disclosures in the financial statements, and add more transparency in the auditor’s report about the auditor’s work. Information about the enhancements to auditor reporting and the ISAs that are affected can be found in the Auditor Reporting Fact Sheet.

"The introduction of Key Audit Matters for listed entities is a significant enhancement that will change not only the auditor's report, but more broadly the quality of financial reporting—and therefore the informative value to investors and other key stakeholders," said Linda de Beer, IAASB Consultative Advisory Group (CAG) Chair.  "The IAASB CAG, with its diverse membership base, has unanimously supported and encouraged the IAASB’s formidable leadership in effecting these changes."

The new and revised Auditor Reporting standards will be effective for audits of financial statements for periods ending on or after December 15, 2016. "While culminating an intense effort over the past six years, the release of the final standards is by no means the end of the IAASB’s work on the topic of auditor reporting," noted Kathleen Healy, IAASB Technical Director. "It is essential that the board and staff continue to promote awareness of these standards and facilitate their effective implementation."

To this end, the auditor reporting section of the IAASB’s website has been redesigned and updated, debuting the first components of an "Auditor Reporting Toolkit." Additional resources will be subsequently released, so users should visit the website frequently to stay abreast of the latest guidance and resource materials. The IAASB also plans to undertake a post-implementation review, which will be critical in assessing whether the standards are achieving their intended effects and whether further changes to auditor reporting are needed in the public interest.

UK: HM The Queen to present awards to Young Africans

60 young people including 27 Africans from across the Commonwealth are being recognised as exceptional leaders in their community. These 60 young people are the first ever to receive a prestigious Queen’s Young Leaders Award.

The Award, which will be presented in London by Her Majesty The Queen in June, and is part of The Queen’s Young Leaders Programme, celebrates the achievements of young people who are taking the lead to transform the lives of others and make a lasting difference in their communities.

This year’s Award winners, aged between 18 and 29 and who come from all over the Commonwealth, are working to support others, raise awareness and inspire change on a variety of different issues including; education, climate change, gender equality, mental health and disability equality.

The 27 young Africans honoured include individuals from Cameroon (3), Kenya (3), Mauritius (3), Namibia (1), Nigeria (4), Rwanda (2), Sierra Leone (1), South Africa (3), Swaziland (1), Tanzania (2), Uganda (2) and Zambia (2)

Aaron Hape, a member of the Advisory Panel of young people who advise the Queen’s Young Leaders Programme and from New Zealand said:

"It was a truly humbling experience to see the kind of work that young people are carrying out across the Commonwealth, and across a diverse range of issues. As a panel member I feel very proud to have been given the opportunity to work with the Programme and be part of selecting the very best from an already amazing pool of talented young people."

The Queen’s Young Leaders Programme is a new initiative established by The Queen Elizabeth Diamond Jubilee Trust in partnership with Comic Relief and the Royal Commonwealth Society in recognition of The Queen’s lifetime of service to the Commonwealth. Over the next four years the Programme will support thousands of young people. In addition to the Queen’s Young Leaders Awards, the Programme will provide grants to support organisations in selected countries across the Commonwealth that work with young people to transform their lives.

Dr Astrid Bonfield CBE, Chief Executive of The Queen Elizabeth Diamond Jubilee Trust said:

"The leadership of talented young people in all spheres of life can transform communities and societies for the better. What the 60 young people announced today have achieved is remarkable and their plans for the future are truly inspiring. The Queen’s Young Leaders Programme is poised to unlock the potential of this diverse and talented group of young people and we are delighted to be supporting them to go further and achieve more."

China in Africa: One among many

China has become big in Africa. Now for the backlash

The Economist

Swiss National Bank discontinues minimum exchange rate and lowers interest rate to –0.75%

The Swiss National Bank (SNB) is discontinuing the minimum exchange rate of CHF 1.20 per euro. At the same time, it is lowering the interest rate on sight deposit account balances that exceed a given exemption threshold by 0.5 percentage points, to −0.75%. It is moving the target range for the three-month Libor further into negative territory, to between –1.25% and −0.25%, from the current range of between −0.75% and 0.25%.

The minimum exchange rate was introduced during a period of exceptional overvaluation of the Swiss franc and an extremely high level of uncertainty on the financial markets. This exceptional and temporary measure protected the Swiss economy from serious harm. While the Swiss franc is still high, the overvaluation has decreased as a whole since the introduction of the minimum exchange rate. The economy was able to take advantage of this phase to adjust to the new situation.

Recently, divergences between the monetary policies of the major currency areas have increased significantly – a trend that is likely to become even more pronounced. The euro has depreciated considerably against the US dollar and this, in turn, has caused the Swiss franc to weaken against the US dollar. In these circumstances, the SNB concluded that enforcing and maintaining the minimum exchange rate for the Swiss franc against the euro is no longer justified.

The SNB is lowering interest rates significantly to ensure that the discontinuation of the minimum exchange rate does not lead to an inappropriate tightening of monetary conditions. The SNB will continue to take account of the exchange rate situation in formulating its monetary policy in future. If necessary, it will therefore remain active in the foreign exchange market to influence monetary conditions.

National Geographic Unique Lodges of the World

In spectacular places all over the world, we have singled out rare retreats where beautiful accommodations and gourmet cuisine are just a small part of a much greater equation. These are not simply hotels, they are the concepts of dreamers come to fruition: unique lodges that defy the imagination in their design and detail, founded on a deep desire to protect the cultures and precious ecosystems that surround them.

National Geographic Unique Lodges of the World is a network of world-class accommodations where sustainability is the touchstone and the guest experience is exceptionally rich and meaningful. We invite you to discover how “staying” can be truly extraordinary. 

What is an IFSC and how does it work?

An international financial services centre caters to customers outside the jurisdiction of domestic economy, dealing with flows of finance, financial products and services across borders

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Mauritius - Percy Mistry: “Get rid of your Bihari Style of Politics”

Why ‪‎Ramgoolam‬ was a failure. Why ‪SAJ‬ will probably fail too…  A “friend of Mauritius” delivers a wake-up call to our government, private sector and to a nation stuck with a ‪Bihari‬ attitude.

ION News

IRS Unleashes Global FATCA Data Exchange, Offshore Transparency Everywhere

FATCA requires foreign banks to disclose the identity and details of Americans with foreign accounts over $50,000. Non-compliant institutions worldwide could be frozen out of U.S. markets, so everyone is complying. Now, the IRS has unleashed a new data exchange to implement the law. The IRS announced the opening of the International Data Exchange Service (IDES). Financial institutions and host country tax authorities will use IDES to securely send their information reports on financial accounts held by U.S. persons to the IRS.

Forbes

The Lawyer Southeast Asia Elite 2015

The Lawyer’s new Southeast Asia Elite report contains the most detailed research available on the local firms that are leading the way in the 10 Association of Southeast Asian Nations (ASEAN) region.

It reveals which firms are best positioned to take advantage of the unified market and those that are true leaders in their individual markets, as well as which international firms have gained the greatest foothold in the region.

Inside the report:

• The different drivers behind each of the 10 ASEAN nations
• What changes law firms can expect when the AEC comes into force
• Which firms are at the forefront of the change in each individual market, with firm-by-firm profiles of each
• Which international firms have the strongest grasp of the region

UK announces plans to join Asian Infrastructure Investment Bank

The Chancellor of the Exchequer, George Osborne is announcing today (12 March 2015) that the UK intends to become a prospective founding member of the Asian Infrastructure Investment Bank (AIIB). In doing so, the UK is the first major Western country to seek to join the AIIB.

Once fully operational the AIIB will support access to finance for infrastructure projects across Asia, using a variety of support measures - including loans, equity investments, and guarantees - to boost investment across a range of sectors including transportation, energy, telecommunication, agriculture and urban development. This support can complement the work already done in the region by existing Multilateral Development Banks such as the World Bank and Asian Development Bank.

As the first major Western country to apply to become a prospective member of the AIIB, the UK will join discussions later this month with other founding members to agree the Bank’s prospective Articles of Agreement, setting out the governance and accountability arrangements that underpin the AIIB’s operating practices.

As part of these discussions the UK will play a key role in ensuring that the AIIB embodies the best standards in accountability, transparency and governance, which will be essential to ensuring the success of the initiative and to unlocking the potential benefits for the wider global economy.

The Chancellor of the Exchequer, George Osborne said:

I am delighted to announce today that the UK will be the first major Western country to become a prospective founder member of the Asian Infrastructure Investment Bank, which has already received significant support in the region. 

This government has actively promoted closer political and economic engagement with the Asia-Pacific region and forging links between the UK and Asian economies to give our companies the best opportunity to work and invest in the world’s fastest growing markets is a key part of our long term economic plan. Joining the AIIB at the founding stage will create an unrivalled opportunity for the UK and Asia to invest and grow together.

African economic growth: The twilight of the resource curse?

Africa’s growth is being powered by things other than commodities

The Economist

Private equity in India: Once overestimated, now underserved

General partners can use lessons from the past decade to build a new and better future.

This article explores the reasons why expectations may have been overly rosy, the headwinds that few investors escaped, and the behaviors that firms fell into. As the industry matures and resets its sights more realistically, a new wave of growth seems within reach. Five factors can tilt the balance: an increase in a bias in favor of control investments, appreciation of the complexity of family-owned businesses, new supplies of mezzanine financing, greater scrutiny from limited partners over general-partner strategies and capabilities, and encouragement from regulators.

Carey Olsen: Royal Court provides guidance to Jersey trustees involved in foreign divorce proceedings

The judgments in the Representation of HSBC International Trustee Limited [2011] JRC 167 and [2014] JRC 254A address important questions of (i) when trustees of Jersey trusts should submit to the jurisdiction of foreign courts in matrimonial proceedings involving beneficiaries of Jersey trusts, (ii) the circumstances in which a Jersey trustee might make a distribution of assets from a Jersey trust to enable a beneficiary to meet his or her obligations to a former spouse pursuant to an order of a foreign matrimonial court and (iii) the circumstances in which an express power in a Jersey trust instrument to remove or exclude a beneficiary may properly be exercised.

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FT Guest post: promoting the renminbi will drive China’s financial reforms

For the renminbi to go truly global it needs more than just cross-border trade flows. China needs to make giant strides in the opening of its domestic capital markets to allow renminbi to flow more freely between China and the rest of the world. This will speed up the renminbi’s emergence as an investment currency and bring the ultimate convergence of onshore and offshore markets closer.

The renminbi is already convertible under the current account and the offshore market is showing strong organic growth. At the end of November last year, offshore renminbi deposits exceeded Rmb1.85tn, up from Rmb1.35tn at the end of 2013 and Rmb315m at the end of 2011. We are optimistic that these flows will continue to accelerate as the proportion of China’s total trade settled in renminbi increases. 

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Forbes Best Countries for Business 2014: Mauritius Ranked 34th Worldwide

Mauritius is the only African country among the top 40 economies worldwide for doing business, according to the Forbes ninth annual survey of the Best Countries for Business 2014 released in December 2014.

The country which stands at the 34th position worldwide is followed by South Africa, Botswana and Zambia which figure at the top 4 African nations placed at the 43rd, 69th, and 70th place respectively.

Forbes rates 145 countries on 11 metrics, including property rights, innovation, taxes, technology, corruption, freedom (personal, trade and monetary), red tape, investor protection and stock market performance.

According to Forbes, several factors have contributed into ranking the country as the top African country for business. They are namely, a more equitable income distribution, increased life expectancy, lowered infant mortality and a much improved infrastructure, since the country has gained independence in 1968.

The survey also shows that Mauritius, which has developed from a low-income agricultural based economy to a middle-income diversified economy, has registered a growth in the range of 5% to 6% from independence.

Forbes further points out that Mauritius has attracted more than 32 000 offshore entities from across India, South Africa and China and investment in the banking sector has reached over one billion US dollar in 2013. Mauritius, according to the report, with its strong textile sector has also been well poised to take advantage of the Africa Growth and Opportunity Act (AGOA) and the country sound economic policies and prudent banking practices have helped mitigate negative effects of the global financial crisis in 2008-2009.

It concludes that Gross Domestic Product has grown in the range of 3%-4% per year for the period 2010-2013 and the country continues to expand its trade and investment outreach across the globe.

The survey was based on values calculated till December 2014 from market performance based on each country’s major stock index returns for 12 months sourced from Freedom House, Heritage Foundation, Property Rights Alliance, Transparency International, World Bank and World Economic Forum.

It will be recalled that Mauritius also tops Africa's Sub-Saharan economies and is ranked at the 28th position worldwide on Overall Ease of Doing Business 2015, according to the World Bank group's Doing Business 2015 Report entitled: Going Beyond Efficiency, released in October last year. Mauritius has climbed one place compared to its 29th position in Overall Ease of Doing Business 2014 and has the region’s highest ranking.

UK: Politicians trusted less than estate agents, bankers and journalists

New polling by Ipsos MORI shows that the British public are less likely to trust politicians to tell the truth than estate agents, bankers and journalists.

Just 16% of Britons trust politicians to tell the truth compared with 22% trusting journalists and estate agents and 31% who trust bankers.

This question has been asked consistently since 1983, making it the longest-running series on trust in key professions in the UK. This helps highlight that low trust in politicians is long-standing: only 18% trusted them to tell the truth in 1983, and they reached a low point of only 13% trusting them in 2009, in the wake of the expenses scandal.

Other key findings include:

• Doctors remain clearly the most trusted profession, with 90% trusting them to tell the truth
• Other key public service professions are also highly trusted, including teachers (86%), the police (66%) and civil servants (55%)
• Civil servants in particular have seen a large increase in trust since 1983: only 25% said they trusted civil servants to tell the truth in 1983 compared with 55% now
• There has also been a consistent increase in trust in scientists in recent years: now 83% trust scientists to tell the truth, compared with 63% in 1997
• In contrast, trust in the clergy/priests has declined significantly, from 85% in 1983 to 71% now
• Trust in bankers has bounced back from 2013, when only 21% trusted them to tell the truth to 31% saying they trust them now
• Managers in the NHS have also seen an increase in trust, from 40% when it was last asked in 2011 to 49% now

 Bobby Duffy, Director of the Social Research Institute at Ipsos MORI said:

“These long term trends remind us that the crisis of trust in politicians is nothing new – we were measuring similarly low levels of trust over 30 years ago.  But that doesn’t make it any less serious a challenge, particularly as we come up to an election that will be fiercely fought. 

This long-running study also shows that trust levels are not fixed, and do shift as the context changes – which is seen particularly in the increasing trust in scientists and civil servants and decreasing trust in the clergy.”

• Download topline results (PDF)
• Download chart (PDF)
• Download full computer tables (PDF)

Mauritius: Driving licences - Penalty points reset to zero

Penalty points for driving licences are being reset to zero as from 1st January 2015, the Ministerof Public Infrastructure and Land Transport, Mr N. Bodha, announced at the end of last year.

As from the same date, the penalty point system is being suspended and the fifty speed cameras disabled, the Minister also said. This policy would be in force for a period of two months, the time to reach a consensus at the level of the ministry experts, police force and road users for a review of the whole system.

The authorities are also considering lowering the fine for speeding, from Rs2000 to Rs500, for the first offence. For a second offence, a higher fine will be imposed. In case of recidivism for the third time, the penalty will be locatedat the points.

Another measure relates to speed limits on the highway. Only two speed limits will be imposed,as appropriate:80 km/hand 110km/h. The speed cameras will also be calibrated to allow for a certain tolerance.

As for motor cycle riders, it will no longer be possible to continue riding with a single learner for years. Riders will be required, after a time frame, to be in possession of a full licence. In that context, the setting up of motorcycle schools will be encouraged.

CPA:18 - Global Acquires $72 Million Long-Term Net-Leased Mauritius Resort Hotel

W. P. Carey Inc., a global net-lease REIT specializing in corporate sale-leaseback, build-to-suit construction financing and the acquisition of single-tenant net-lease properties, announced today that CPA®:18 – Global, one of its managed non-traded REITs, has acquired a 266-room resort hotel, La Plantation d'Albion Club Med, located in Albion, Mauritius, for approximately $72 million (€59 million).

The facility is triple net-leased to Holiday Village Management Services Ltd, a subsidiary of Club Mediterranee SA (Club Med,), for an initial term of 15 years. The lease is guaranteed by Club Med, the renowned pioneer in all-inclusive resorts.  

Key Facts

• Upscale resort property: La Plantation d'Albion, Mauritius is comprised of 266 rooms and suites, two gourmet restaurants, three ocean view bars, two beaches and a health club, as well as three large swimming pools, a mini golf course and tennis courts. The resort is categorized as a 5-Trident resort, which is the highest level of quality offered within Club Med resorts worldwide.
• Well-located property: Mauritius is an island nation in the Indian Ocean approximately 1,200 miles off the southeast coast of the African continent. Situated on 53.4 acres of natural tropical woodland, the resort's location on the northwestern coast of the island supports Club Med's up-market strategy, as well as its increased focus on the growing Asian tourism market.
• Stable international investment: One of only two Club Med 5-Trident resorts in the world, the property has shown stable performance since its development in 2007 despite wider global economic turmoil. Its up-market focus and price point have enabled the resort to generate solid returns. Mauritius ranks 20th in The World Bank's "Ease of Doing Business Index," which evaluates economies based on how conducive the regulatory environment is to starting and operating a company.
• Triple-net, inflation-protected euro lease: The facility is leased for a period of 15 years. Rent is paid in euros with annual increases tied to the European Consumer Price Index. The lease is guaranteed by Club Med, a leader in the upscale all-inclusive resort space that owns, leases and manages 66 resorts and one cruise ship, with around 46,000 beds and related facilities.

Management Commentary

W. P. Carey Managing Director and Co-Head of Global Investments, Jason Fox:

"This transaction offered the opportunity for CPA®:18 – Global to acquire an internationally branded upscale beach resort in a leading tourism destination. The deal demonstrates our ability to access a wider pool of global investment opportunities that meet our established investment criteria in order to provide long-term value for CPA®:18 – Global's investors. We are pleased to add to the global diversity of the CPA®:18 – Global portfolio with the acquisition of this solid cash flow generating asset with a triple net-lease structured to provide inflation-indexed returns."

Roger Hensman, Advisor to W. P. Carey on the transaction, added:

"W. P. Carey's global investing perspective and experience enabled them to recognize the value of this acquisition as an attractive addition to the CPA®:18 – Global portfolio. Given the quality of the asset and the strength of Club Med as an established resort owner and operator in combination with the triple net-lease structure, the opportunity was consistent with their established investing criteria."

Mauritius: Central bank governor replaced

The government has sacked Rundheersing Bheenick from his post as governor of the Bank of Mauritius (BoM, the central bank), which he has held since 2007. He has been replaced by Ramesh Basant Roi, an ex-governor of the central bank.

The Economist Intelligence Unit

STEP Mauritius Conference 2015 - Opening doors to Africa and beyond

At a time when significant changes are taking place in worldwide trust jurisdictions, the second STEP conference in Mauritius will bring together a blend of renowned industry experts for two days of highly insightful content and information.

The agenda will range from providing regional updates and identifying the opportunities and challenges with the new Mauritius-South Africa Double Taxation Agreement to more international issues, such as the International AML/CFT initiatives and the future of IFCs. Other local topics will include an update on the Indo-Mauritius DTA and GAAR implications and an exploration of structuring investments into Africa through Mauritius.

With sessions on the philanthropic and commercial uses of trusts and foundations, obligations under anti-corruption and asset recovery legislation and recent sham trust court cases from South Africa, this is an evidently, highly topical and must-attend event. 

Register your place now to avoid disappointment. 

26 - 27 March 2015, InterContinental Resort Mauritius

Registration and payment options 

Delegate Fee

• STEP Member (Local) - GBP 300.00
• Non-Member (Local) - GBP 400.00
• STEP Member (International) - GBP 750.00
• Non-Member (International) - GBP 850.00

Welcome cocktail reception and dinner included in the delegate fee, guests are chargeable 

Guest Fee

• Welcome cocktail reception - Complimentary 
• Reception and dinner - GBP 60.00

UK: Taxman reveals top 10 terrible tax excuses

Ten of the most terrible excuses for missing the 31 January tax return deadline have been revealed today by HM Revenue and Customs (HMRC).

Many of the excuses claim it was someone else’s fault – pets, girlfriends, work colleagues and even the President of the United States are named and blamed for taxpayers’ tardiness.

The excuses were all used in unsuccessful appeals against HMRC penalties for late filing and payment. Here’s the full list:

• My pet dog ate my tax return…and all the reminders.
• I was up a mountain in Wales, and couldn’t find a postbox or get an internet signal.
• I fell in with the wrong crowd.
• I’ve been travelling the world, trying to escape from a foreign intelligence agency.
• Barack Obama is in charge of my finances.
• I’ve been busy looking after a flock of escaped parrots and some fox cubs.
• A work colleague borrowed my tax return, to photocopy it, and didn’t give it back.
• I live in a camper van in a supermarket car park.
• My girlfriend’s pregnant.
• I was in Australia.

HMRC Director General of Personal Tax, Ruth Owen, said:

People can have a genuine excuse for missing a tax deadline, but owning a pet with a taste for HMRC envelopes isn’t one of them.

You need to file your 2013/14 tax return online, and pay what you owe, by 31 January. But it’s best to do it now, to allow plenty of time to sort out any issues with your return. That way, you’ll avoid the busy period for our phone lines as the deadline approaches.

All outstanding 2013/14 tax returns must now be submitted online, as the 31 October paper-filing deadline has passed. To send an online tax return, you must be registered for HMRC Online Services. This involves HMRC sending you an Activation Code in the post, and you need to allow 10 days for it to arrive.

IFC Review - Caribbean IFCs: Well Regulated Parts of the International Furniture

Anthony Travers addresses criticism regarding the regulatory systems in Caribbean IFCs and questions whether their onshore counterparts should look a little closer to home

IFC Review: Bermuda and the Push Towards Automatic Exchange of Information

Charles Thresh and David Harper consider the implications of the OECDs Automatic Exchange of Information Drive for Bermuda's financial services sector

Ile Maurice: Les acquisitions foncières d’une Française jugées illégales

Elle réclamait des droits sur des bungalows que son époux avait achetés avant leur mariage. Toutefois, la Cour suprême a estimé qu’elle n’avait pas le droit d’acquérir des propriétés à l’époque, pour une question de nationalité. Cette Française voulait récupérer des biens que possédait son ex-époux, mais qu’elle dit avoir achetés. Pour cela, elle a fait une demande en Cour suprême.

Le Défi

Castille in Mauritius

Specialised recruitment agency Castille opened its doors in Mauritius at the beginning of 2014 and has since grown into a reputable force in Africa.

One year on, it has built sustainable relationships with a number of banks, financial institutions, telecom and ICT companies, offering the same quality service offerings as found by its counterparts in Malta including specialist search and selection, talent outsourcing and executive search.

The Castille regional office in the Indian Ocean is managed by Andrew Ragaven with the assistance of Vandana Yenkadu. Companies are approaching the Castille Mauritius office with a keen interest to set up remote teams possessing skills in IT, finance and accounting.

A large proportion of the working population in Mauritius possesses degrees and accreditations from reputable worldwide institutions.

Moving into 2015, the Mauritius office intends to continue growing its team and drive its quality services to companies across the African and European continents.

Aspects of the draft Mauritius/South Africa treaty designed to prevent treaty abuse

The draft treaty between Mauritius and South Africa applies to normal tax, to withholding taxes on royalties and on foreign entertainers and sportsmen and the secondary tax on companies (which has been abolished). Although dividends tax has not been expressly included in Article 2 of the draft treaty, Mauritius has been advised by SARS that it will form part of the treaty, which Mauritius has implicitly accepted.

(a) Mutual agreement on residence

The most significant change brought about by the draft treaty concerns companies that are tax resident in both Mauritius and South Africa. In terms of the OECD Model Tax Convention tie breaker rules, double taxation of dual residents companies is resolved by ensuring that the company is tax resident in the State in which its “place of effective management” is situated. A South African incorporated company which is effectively managed in Mauritius would thus, in terms of the OECD tie breaker rules, be deemed to be tax resident in Mauritius and South Africa would lose its "taxing rights”. One of the perceived “abuses” of the 1997 Mauritius/South Africa treaty is by companies incorporated in Mauritius that purport to be effectively managed there, but are in fact run from South Africa. That is the case where significant functions that benefit the Mauritian company’s operations take place in South Africa.

Under the draft treaty the draft dual-residence tiebreaker rules provide that the competent authorities of the two states shall endeavour to determine by mutual agreement the Contracting State of which such person shall be deemed to be resident for the purposes of the treaty. This “mutual agreement procedure” as a manner for determining the tax residence status of a taxpayer is contemplated by the commentary on Article 4 of the OECD Model Tax Convention. The alternative provision provides that, in endeavouring to come to agreement on where the taxpayer shall be deemed to be resident, regard must be had to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. Where it is clear as to where the company is in fact effectively managed, such a provision would bring about no change. Accordingly, companies that are currently incorporated in Mauritius and are clearly managed there will not be affected by this provision. In a case where both South Africa and Mauritius believe that a company is incorporated in and purportedly effectively managed in Mauritius, and is also managed in South Africa, South Africa may wish to assert that the company is resident in South Africa. Unless South Africa and Mauritius can agree on where the company is resident, it will be a resident, for treaty purposes, of both countries and taxable in both countries. The contracting states are not required to grant the dual resident entity treaty benefits. 

There is no obligation on the competent authorities to reach an agreement on the residency of an entity and it is probably practical to assume that the chances are remote of reaching agreement swiftly or even at all. The competent authority of Mauritius, for example, would, in principle, not have an active interest in coming to a mutual agreement where this would involve losing its taxing rights to South Africa. The fate of a dual resident company is that there is the potential for it to suffer tax in both countries but the effect of this could be ameliorated by any applicable domestic exemptions or credits (such as section 6quat). However, because Mauritius is a low tax jurisdiction, domestic relief for foreign tax paid is unlikely to offset the disadvantage of being subject to tax in both states (especially in light of the repeal of the tax sparing clause).

The practical effect of the above is that the dual resident company will be denied the benefits of the treaty and be subject to double taxation in South Africa and Mauritius if no agreement is reached between the two contracting states regarding the residence of the company. A binding arbitration process as per the current provisions of the OECD is not applicable under the proposed treaty. 

Some consequences of the draft treaty are:

• It may force companies to stop creating dual residence situations. The draft treaty will necessitate taxpayers to relook their position as it places the onus on them to ensure that they structure effective management and substance of their entities so as to avoid double taxation. Since the Mauritian tax rates are lower than those in South Africa, it could imply that South African companies will also be unable to benefit from the section 6quat rebate if effective management is deemed to be in South Africa. The double taxation impact could result in decreased South African FDI into Mauritius – albeit minimal.
• The draft treaty widens South Africa’s tax net as it increases South Africa’s ability to identify Mauritian companies that should be regarded as resident here, given the way in which they in fact operate.
• The draft treaty may also help to bring into the tax net certain Mauritian branches of South African companies, in that, if the branch houses the company’s only activity, it may be possible to claim that the company is dual resident by virtue of incorporation in South Africa and effective management in Mauritius.
• The draft treaty does not affect Mauritian companies that clearly have their effective management in Mauritius.

(b) Withholding rates

Interest: Under the current treaty, interest paid out of South Africa to a Mauritian beneficial owner would not be taxable in South Africa. Under the draft treaty, the amount that South Africa is able to withhold on interest paid to a Mauritian beneficial owner has increased from nil to 10% of the gross amount of the interest. Mauritius does not currently impose a withholding tax on interest paid. South African lenders to Mauritian borrowers would thus not be negatively affected by the amendment of the interest article, while on the other hand Mauritian lenders to South African borrowers would be affected.

Dividends: In terms of the draft treaty, dividends tax will be withheld at a 10% rate unless the beneficial holder of the dividend holds at least 10% of the capital of the company paying the dividends, in which case the tax will be 5%.

Royalties: In terms of the draft treaty, the amount that South Africa is able to withhold on royalties paid to Mauritius has increased from nil to 5%. The above withholding tax rates will have an impact on Mauritian financing or IP licensing entities that derive Interest or royalty income from South Africa.

(c) Capital Gains Tax (CGT) Carve-Out for Property Rich Companies

As noted above, apart from being a low tax jurisdiction in which to operate, Mauritius has also been a favourable base for investing into South African land rich companies. The draft treaty provides that capital gains earned by Mauritian tax residents could be subject to South African CGT if the gain is from the disposal of shares in a South African company holding immovable property - a “land rich” company. This will have an impact on Mauritian companies that currently hold South African based investments in the mining or property sector. Thus the capital gains article of the draft treaty repeals the so called “CGT cut out” clause as it specifically provides that a country may tax gains derived from the alienation of shares deriving more than 50% of their value directly or indirectly from immovable property situated in that country.

However, this gives rise to the potential for investors to channel this type of investment through companies in other countries that still have a treaty with South Africa that still have CGT cut out clause. This was the case for example with the previously South Africa/Netherlands treaty. However, the South Africa/Netherlands DTA has been renegotiated and is awaiting signature and so is South Africa/Luxembourg DTA. It is also worth noting that the South Africa/Austria DTA and 18 other DTAs that have a zero rate on interest and/or royalties and those that do not have 13(4) of OECD are under renegotiation. These renegotiations will ensure Changes in ownership of shares in Mauritian land rich companies prevent the incentive to change the ownership to residents in other treaty countries now that there is South African CGT on disposal. 

(d) Tax Sparing

The draft treaty no longer includes a tax sparing clause. Rather, it allows for relief in the form of a foreign tax credit.

(e) Exchange of information on tax matters and assistance in the collection of taxes

The 1996 tax treaty has a limited version of exchange of information provision that does not extend to bank secrecy. The draft tax treaty contains the latest OECD standard for the exchange of taxpayer information on tax matter as set out in article 26 of the OECD MTC. This will assist in the auditing of South African residents domiciled in Mauritius. The treaty also contains provision relating to assistance in tax collection of taxes.

(f) Remarks and Recommendations

There is no doubt that the draft treaty (if ratified) will put Mauritian companies in a less beneficial position vis-à-vis South Africa than is currently the case. This is so, specifically in the context of dual-resident companies, loans to South African borrowers and investments in companies owning immovable property in South Africa. However, this does not necessarily mean that the use of Mauritian companies is no longer beneficial in international structures.

It should be noted that treaty shopping can never be entirely stamped out and the chances are that some multinationals may look to other tax treaties to avoid having to pay CGT. One must bear in mind that the withholding taxes in the draft treaty are still lower than the normal South African holding tax rate. Where there is an entity in a third county either from which the Mauritian incorporated dual resident entity is receiving payments or to which it is making payments, being a dual resident could offer the advantage of the ability to cherry pick treaty rates. The dual resident company may thus be able to avail itself of either the tax treaty that South Africa has with a third country or of the tax treaty that Mauritius has with the third country. In these circumstances, since the “mutual agreement procedure” has to be initiated by the taxpayer, where the taxpayer takes advantage of other treaties, it would be difficult for such a taxpayer to initiate the mutual agreement procedure. In the absence of a specific fact scenario it is difficult to predict the extent to which the ability of a dual resident to “cherry pick” could lead to revenue leakage for South Africa, but it is a matter to be borne in mind during future risk profiling of Mauritian structures.

The withholding tax rates provided for in the draft treaty are still lower than the normal South African withholding tax rates. Although headquarter companies enjoy exemptions from these withholding taxes, headquarter companies cannot be used for investment into South Africa. Foreign investors would thus still prefer investing into South Africa via Mauritius, or they could look for another suitable jurisdiction to act as holding company jurisdiction for investment into Africa, including South Africa.

IFC Review - Keeping Pace with the Ever Changing World in Which We Practice

Morven McMillan examines the latest trends in the trust and wealth management industry and casts her eye over future developments facing the industry

IFC Review - Riding the Waves of Change: Balancing Compliance with Confidentiality

Nadia Fountain examines how The Bahamas can comply with international regulatory stands while maintaining the confidentiality of clients