A new clause in Mauritius income tax law poses headache to Indian investors

Experts believe the SOP will make it more difficult to obtain a TRC from the Mauritian authorities

Mauritius has amended its Income Tax Act and inserted a clause for determining the place of effective management. This makes it difficult to establish residency in the country and poses a new headache to Indian private equity as well as portfolio investors putting money into the country.  

The Mauritius Revenue Authority (MRA) issued a Statement of Practice (SOP) on November 28, with regard to Section 73A of the Income Tax Act on place of effective management. The place of effective management is part of the international best practices, aimed at ensuring that sufficient economic activity happens in a particular country. 

Experts believe