Amendments will be brought to the Double Taxation Avoidance Agreement (DTAA) between Mauritius and Germany to ensure compliance with the Base Erosion and Profit Shifting (BEPS) project recommendations through the signing of a protocol (the “Protocol"). The Protocol will make for the following new provisions:

• a statement in the Preamble to emphasise that the intention of both countries is to eliminate double taxation, without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance;
• the possibility for a taxpayer to have recourse to arbitration where a tax dispute cannot be resolved by the competent authorities within a period of three years after the case has been referred for consideration; and
• to clarify the cases which are not eligible for arbitration