South Africa Mauritius Double Tax Agreement

Where a company is established in both Contracting States, the competent authorities shall determine by mutual agreement the domicile of the company for the purposes of the Treaty. If the authorities do not reach a mutual agreement, the undertaking is considered outside the scope of the Treaty, with the exception of the provisions of Article 25 (exchange of information). The old tax treaty contained a «tax saving» provision, but it was removed from the new agreement. Under a tax-free provision, the foreign investing country grants the inclusion of notional taxes that the country of investment waives due to tax incentives or holidays in the country of investment. However, some feared that the provision of the old treaty had been used for «double non-taxation».