Mauritius has gazetted the amending protocol (Government Notice No. 182 of 2024) to the 2009 Double Taxation Avoidance Convention (BM DTC) with Bangladesh.
The amending protocol was signed by Mauritius on 5 February 2024 and sent to Bangladesh through diplomatic channels, which was signed by Bangladesh on 9 April 2024.
The 2024 Protocol introduces updates, including a “principal purpose test” to prevent treaty abuse, aligning with OECD/G20 BEPS Action 6. Key revisions extend the 10% withholding tax rate on dividends to interest, royalties, and technical fees. Changes to capital gains tax rules aim to curb abusive practices, targeting cases involving immovable property.
Enhanced cooperation on tax enforcement, information exchange, and mutual agreements will now follow OECD’s 2017 Model Tax Convention guidelines.
“As a result of signing the amended protocol, Bangladesh will be able to levy tax at a rate of 10% to 15% on income from royalty, capital gains, interest, and technical know-how,” A senior official of National Board of Revenue of Bangladesh (NBR) told The Business Standard, a local English daily. “Bangladesh has had a DTAA with the country since 2012. However, it has been recently revised with certain amendments, leading to its re-signing as a DTAA protocol.”
The protocol will take effect after the ratification instruments have been exchanged.