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Tax Treaty Network
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Country
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Project duration for permanent establishment purposes
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Maximum Tax Rates applicable in the country of source
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Dividends |
Interests |
Royalties |
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Belgium
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> 6 Months
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5% & 10% (a)
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10%
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0%
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Botswana
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> 12 Months
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5% & 10% (b)
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12%
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12.5%
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China
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> 12 Months
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5%
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10%
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10%
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Cyprus
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> 6 Months
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0%
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0%
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0%
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France
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> 6 Months
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5% & 10% (a)
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Same rate as under domestic law
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15%
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Germany
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> 6 Months
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5% & 15% (b)
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Same rate as under domestic law
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15%
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India
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> 9 Months
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5% & 15% (a)
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Same rate as under domestic law
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15%
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Indonesia
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> 6 Months
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5% & 10% (c)
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10%
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10%
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Italy
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> 6 Months
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5% & 15% (b)
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Same rate as under domestic law
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15%
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Kuwait
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> 9 Months
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0%
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5%
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10%
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Luxembourg
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> 6 Months
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5% & 10% (a)
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0%
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0%
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Madagascar
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> 6 Months
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5% & 15% (b)
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10%
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15%
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Malaysia
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> 6 Months
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5% & 15% (a)
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10%
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15%
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Mozambique
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> 6 Months
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8%,10% & 15% (b) & (f)
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8%
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5%
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Namibia
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> 6 Months
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5% & 10% (b)
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10%
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5%
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Nepal
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> 6 Months
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5%(d) & 10%(b)
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10% & 15%
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15%
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Oman
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> 6 Months
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0%
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0%
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0%
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Pakistan
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> 6 Months
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10%
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10%
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12.5%
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Singapore
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> 9 Months
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0%
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0%
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0%
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South Africa
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> 9 Months
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5% & 15% (a)
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10%
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5%
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Sri Lanka
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> 183 Days
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10% & 15% (a)
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10%
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10%
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Swaziland
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> 6 Months
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7.5%
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5%
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7.5%
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Sweden
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> 6 Months
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5% & 15%
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10%
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15%
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Thailand
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> 6 Months
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10%
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10% & 15% (e)
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5% & 15% (c)
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United Kingdom
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> 6 Months
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10% & 15% (a)
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Same rate as under domestic law
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15%
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Zimbabwe
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> 6 Months
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10% & 20% (b)
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10%
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15%
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(a) Lower rate applies to companies holding at least 10% of capital.
(b) Lower rate applies to companies holding at least 25% of capital.
(c) Lower rate applies to companies holding at least 20% of capital.
(d) Lower rate applies to companies holding at least 15% of capital.
(e) Lower rate applies if paid to any Bank carrying on a bona fide banking business.
(f) Higher rate applies to companies holding investment other than portfolio investment.
Tax Residency
A Global Business Category 1 Company wishing to benefit from the tax relief under the Double Taxation Agreements, requires a Tax Residence Certificate (TRC), which is issued by the Commissioner of Income Tax in Mauritius. To be tax resident, the company must demonstrate that the "effective management and control'' is in Mauritius. To satisfy this test the applicant company is required to:-
Have at least two resident directors in Mauritius.
- Chair and initiate Board Meetings from within Mauritius.
- Maintain an account with a local bank through which funds must flow.
- Maintain its registered office and all statutory records in Mauritius.
- Have a local qualified company secretary.
- Have a local auditor.
Investors should ensure that the above relevant conditions are also satisfied in the country of investment to guarantee eligibility of DTA benefits.
Alliance Trust provides professional resident directors who will initiate and chair board meeting.
