India’s Notification No. 135/2026 confirmed that the amending protocol to the 1982 income and capital tax treaty with Mauritius entered into force on 10 August 2026, introducing a new Article 27B (Entitlement to Benefits) and aligning the treaty preamble with OECD BEPS standards.
India has issued Notification No. 135/2026, confirming that the amending protocol to the 1982 income and capital tax treaty with Mauritius entered into force on 10 August 2026.
The protocol, signed on 7 March 2024, replaces the treaty preamble to align it with OECD BEPS standards and introduces a new Article 27B (Entitlement to Benefits).
Article 27B restricts treaty benefits where obtaining them was one of the principal purposes of an arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the relevant treaty provisions.
The protocol generally applies from 10 August 2026, regardless of the tax levy date or relevant taxable year.
Earlier, Mauritius’ Cabinet approved regulations to bring into force the 2024 Protocol amending the India, Mauritius Double Taxation Avoidance Agreement (DTAA).
