India: Protocol to income tax treaty with Mauritius enters into force, incorporates principal purpose test
Amends treaty to incorporate anti-abuse provisions similar to those in MLI, including principal purpose test
The protocol to the India-Mauritius income tax treaty, which was signed in 2024, entered into force on August 10, 2026.
As the treaty is not a covered tax agreement under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the protocol amends the treaty to incorporate the anti-abuse provisions similar to those contained in the MLI, including a principal purpose test.
Read an October 2026 report prepared by the KPMG member firm in India