Negative impactEconomy HIGH IMPACT

India-Mauritius tax treaty amended to curb treaty abuse; PPT test introduced

BusinessLine 1 hr ago·14 Oct 2026, 11:48 am

India has amended its tax treaty with Mauritius to curb treaty abuse. The new rules introduce a 'Purpose and Substance Test' to ensure that transactions claiming treaty benefits are genuine and have a real commercial purpose.

This change is significant for investors because it reduces the likelihood of tax avoidance strategies that previously allowed capital gains from foreign investments to be taxed at zero. While the move is aimed at closing loopholes, it may slightly alter the tax landscape for foreign investors, potentially increasing the cost of doing business in India.

Investors should monitor how this impacts the flow of foreign capital and the valuations of stocks with significant Mauritius-based holdings. The broader market may see a short-term adjustment as the implications of the new rules are digested.

Excerpt from BusinessLine

India and Mauritius have amended their bilateral tax treaty by adding a treaty-level Principal Purpose Test (PPT) to the existing framework, in a move to curb treaty abuse. The amendment also replaces the treaty preamble to say that the pact intends to eliminate double taxation “without creating opportunities for…
Read the original at BusinessLine

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