Mauritius to amend tax treaty with Germany

On October 15, 2021, the Mauritian Cabinet agreed to sign a Protocol to the tax treaty with Germany.

The objective of the Protocol is to amend the tax treaty so that it complies with the OECD’s base erosion and profit shifting recommendations.

The Protocol, would incorporate in the Agreement, the following new provisions:

• a statement in the Preamble to emphasize that the intention of both countries is to eliminate double taxation, without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance
• the possibility for a taxpayer to have recourse to arbitration where a tax dispute cannot be resolved by the competent authorities within a period of three years after the case has been referred for consideration; and
• to clarify the cases which are not eligible for arbitration.

See Release