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Our newsletters cover a variety of tax and financial topics relevant to both individuals and corporations. Make sure to subscribe to our mailing list to get the latest insights on the tax landscape.
Executive Summary: The Supreme Court of Mauritius recently issued a critical judgment in Alteo Energy Ltd v Assessment Review Committee & Anor, providing much-needed clarity on the application of the 80% partial exemption on interest income under the Income Tax Act 1995 (ITA) and Regulation 23D(2) of the Income Tax Regulations 1996 (IT Regulations). This case is particularly significant for businesses seeking to optimise their tax positions while ensuring compliance with the substance requirements prescribed by the ITA.
Do you understand the distinctions between capital contributions and advance against equity (also known as share application monies) for accurate financial reporting and investor transparency?
This article explores these concepts and their impact on the equity section of a balance sheet.
On 21st January 2025, the Central Board of Direct Taxes (“CBDT”) issued a Circular to provide guidance on the Principal Purpose Test (“PPT”) under India’s Double Taxation Avoidance Agreements (“DTAAs”).
The Circular is most welcomed as it provides important clarifications regarding the prospective application of the PPT and its interaction with existing provisions.
Andersen in Mauritius is pleased to present the Taxation Highlights of the Finance (Miscellaneous Provisions) Act 2024, which received presidential assent on 26 July 2024.
The Taxation Highlights covers the salient updates to the tax laws in Mauritius, including the CCR Levy, additional tax exemptions, credits and deductions, VAT updates and changes to tax administration.
Key Issue: Whether the royalty fees paid by Avago Technologies Trading Ltd (ATTL) to its related entity, GEN IP (Singapore), were excessive, not at arm's length, and constituted a tax avoidance arrangement?
Executive Summary: On 4 July 2024, in the matter of Avago Technologies Trading Limited (ATTL) v/s Director General, MRA, the Assessment Review Committee (ARC) ruled in favour of the Mauritius Revenue Authority (MRA) and determined that the royalty fees paid by the Mauritian company were excessive and not at arm's length, constituting a tax avoidance arrangement. The ARC also supported the MRA's position that the royalty fees claimed as deductions by ATTL were inflated to shift profits from Mauritius (where ATTL would have suffered an effective tax rate of 3% on its profits) to Singapore, where the royalty fees were exempt.
On 28 June 2024, the Assessment Review Committee (“ARC”) ruled against the Company by denying the partial exemption claimed on its interest income.
We are pleased to share with you the Andersen Mauritius Budget Highlights 2024/2025. Our analysis covers the essential tax highlights and the implications for you & your business, equipping you with insights which will help you navigate the fiscal landscape.
On 30 May 2024, the Assessment Review Committee (“ARC”) ruled in favour of Mr Julien by allowing the interest relief claimed by Mr Julien in his tax return on a loan contracted by him for the settlement of a previous loan contracted by him and his spouse for the purchase of an apartment jointly owned by them.
The Supreme Court (“SC”) has heard the appeals of both the Mauritius Revenue Authority ("MRA") and Mr Dilloo (together referred to as “the Appellants”), by way of case stated against a decision of the Assessment Review Committee ("ARC").
On 4 March 2024, in the matter of Seacom Ltd v/s Director General, MRA, the Assessment Review Committee (ARC) ruled in favour of the Mauritius Revenue Authority (MRA) on whether interest incurred on loans entered into by Seacom which were used to grant interest free loans to related companies is deductible for corporate tax purposes under section 19 of Income Tax Act (ITA).
