Mauritius: Income tax treaty with Lesotho

Provisions of the income tax treaty are applicable in Mauritius as from 1 July 2021

Provisions of the income tax treaty are applicable in Mauritius as from 1 July 2021

Mauritius and Lesotho have completed their respective ratification procedures for the entry into force of an income tax treaty.

The provisions of the income tax treaty are applicable in Mauritius as from 1 July 2021.

Withholding tax rates under the treaty

Treaty article relating to:

Withholding tax rates under the treaty*

Withholding tax rates, payments made to non-residents from Lesotho



0% / 25%






15% / 25%

Technical service fees



* When the rates under the domestic laws are more favourable than the withholding tax rates under the income tax treaty, the domestic laws will apply.

Capital gains

Under the treaty, capital gains refers to gain from sale of shares of a company deriving at any time during the 365 days preceding the sale, more than 50% of its value from immovable property, Such capital gain will be taxable in the country where the immovable property is situated. 

Limitation on benefits

The treaty includes a limitation on benefits article that generally is in line with measures under the OECD’s Multilateral Instrument (MLI).

KPMG observation

Lesotho is not a signatory to the MLI. 

Read an August 2021 report [PDF 133 KB] prepared by the KPMG member firm in Mauritius


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