KEY FEATURES OF THE DOUBLE TAXATION AVOIDANCE AGREEMENT BETWEEN MAURITIUS AND CONGO

Mauritius and Congo had entered into a Double Taxation Avoidance Agreement (DTAA) on 20th December 2010 and the DTAA has entered into force on 8th October 2014
The DTAA will take effect as follows:

  1. In Mauritius
    • (i) With regard to income, in respect to any income year beginning on or after the first day of January 2015.
  2. In Congo
    • (i) With regard to income, in respect to any income year beginning on or after the first day of January 2015.
    • The main articles of the Mauritius – Congo DTAA have been summarized below:

      Income Withholding tax rate (WHT) under DTAA Dividend 0%/5%(1) Interest 5% Royalties 0%

    • (i) 5% applies where beneficial owner owns at least 25% of the company paying out the dividends/5% applies in all other cases
    • Capital Gains arising from the disposal of immovable properties and shares of companies which owns immovable properties, will be subject to tax in the country where the immovable properties are located. In all other cases, capital gains will be taxed in the country where the alienator is based but in Mauritius, there is no capital gains tax.