Mauritius tax protocol to give Indian taxman more powers to probe offshore entities

July 23, 2026

Mauritius cabinet ratified a tax protocol granting Indian officials more questioning powers. This allows direct challenges to offshore entities suspected of tax evasion. The principal purpose test will deny treaty benefits if tax avoidance is a primary aim. This change follows the Tiger Global verdict and strengthens genuine substance requirements. The protocol aims to ensure treaty benefits are for legitimate commercial purposes.

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