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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

October 14, 2026

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

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