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The Double Taxation Relief (Taxes on Income) (Mauritius) Order 1987
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- UK Statutory Instruments
- 1987 No. 467
- Explanatory Note
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Explanatory Note
(This note is not part of the Order)
The Protocol scheduled to this Order amends the Convention set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Mauritius) Order 1981.
Article 1 of the Protocol replaces Article 10 (Dividends) of the 1981 Convention with a new Article. This includes one important change relating to the tax treatment of dividends paid by Mauritian companies to United Kingdom shareholders following changes made by Mauritius to its method of taxing company profits and distributions. Dividends flowing to the United Kingdom from Mauritius will be subject to tax at a rate not exceeding 10 per cent in Mauritius where the dividends are paid to a company which controls at least 10 per cent of the voting power in the paying company. In all other cases the rate of tax is not to exceed 15 per cent. The tax treatment of dividends paid by a United Kingdom company to a Mauritian shareholder remains unchanged.
The Protocol takes effect in relation to dividends paid on or after 1st July 1986.
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