Protocol amending the Eswatini-MRU Double Taxation Avoidance Agreement (DTAA)

Article Published on October 19, 2020

A Protocol amending the Eswatini-Mauritius DTAA (the “Protocol") was signed by the Mauritian Minister of Finance, Economic Planning and Development in September 2020. In addition to updating the name of the Kingdom of Eswatini (previously known as the “Kingdom of Swaziland"), the main changes brought by the Protocol to the DTAA are as follows:

- “Competent Authority" for Mauritius now refers to the Director-General, Mauritius Revenue Authority or his authorised representative
- an insurance company would be considered as a Permanent Establishment in a Contracting State
- the applicable withholding tax rate on the interest income in the country where such income is sourced has been raised from 5% to 7.5%
- the Article on Exchange of Information has been updated and aligned with the international standard as prescribed by the Organisation for Economic Cooperation and Development
- a new Article has been introduced in the DTAA for mutual assistance in the collection of tax due to the other Contracting State, as a measure to reinforce the fight against tax evasion.