In 2002, India`s contract with India, which underpinned the birth of Mauritius as the dominant channel for foreign direct investment, was attacked by Indian tax authorities in 2002 for allegations of abuse by investors based in India. in October 2006, the Government of Mauritius announced that it would strengthen the rules on the issuance of certificates of tax residence; in the future, it would only expose them for one year at the end. Several other restrictions were imposed on that date, in particular with regard to the issue of global applications for Category 1 operating licences Finally, a protocol for the Indo-Mauritius tax treaty was established in May 2016. As of April 1, 2017, the beginning of the 2017-2018 fiscal year, capital gains from shares of companies established in India were no longer exempt. However, until March 31, 2019, capital gains tax will be levied at 50% of india`s national rate. The DBA with Indonesia was repealed for similar reasons on 1 January 2005, following the resignation of the Indonesian government in 2004 and the refusal to discuss it. No negotiations are currently under way between Mauritius and Indonesia. In this case, the possibility of double taxation is greater, as investment flows are much more complex. So I think there`s evidence that contracts work. The Mauritius Tax Agreement and Act provide for a credit with respect to the underlying tax on dividends and a tax reduction for tax exemptions or reductions granted by a State.

I do not call them double taxation treaties. I call them tax treaties. Indeed, helping companies avoid double taxation is not really the main thing they do. . . .