Mauritius: your gateway to India and Asia

Historic tax treaty with India, CECPA, treaties with China and Southeast Asia: invest in Asia from Mauritius with optimised taxation.

Mauritius-India: a historic bridge unique in the world

The relationship between Mauritius and India has no equivalent in international finance. Cultural, human and economic ties between the two countries date back to the 19th century, when hundreds of thousands of Indian workers arrived in Mauritius following the abolition of slavery. Today, around 68% of the Mauritian population is of Indian origin, and the two countries share deep linguistic (Hindi, Bhojpuri), cultural and diplomatic ties.

On the financial side, the 1982 bilateral tax treaty made Mauritius the top foreign investor in India for nearly four decades, channelling tens of billions of dollars of portfolio investment (FPI) and direct investment (FDI) into the subcontinent. Despite the 2016 revision of the treaty, Mauritius retains a strong strategic position for investment in India, reinforced by CECPA signed in 2021. The typical structure goes through a Mauritian holding company holding the Indian stakes.

Beyond India, Mauritius is developing its ties with the whole of South and Southeast Asia through a network of tax treaties covering China, Singapore, Malaysia, Thailand, Sri Lanka, Bangladesh, Vietnam and other countries in the region.

1982 Mauritius-India tax treaty
CECPA India's 1st FTA with Africa (2021)
10+ Asian tax treaties
3% Effective tax rate on Indian income

The Mauritius-India tax treaty

The tax treaty between Mauritius and India is one of the most important instruments in international finance. Signed in 1982 and revised by protocol in 2016, it is part of Mauritius's network of tax treaties and continues to offer significant benefits for investors structured via Mauritius.

Evolution of the treaty: before and after 2016

Element Before 2016 (original regime) After 2016 (current regime) Practical impact
Capital gains on Indian shares Exempt in India (exclusive taxation in Mauritius) Taxable in India (shared right) Alignment with the India-Singapore treaty
Capital gains on bonds/debt Exempt in India Exempt in India (unchanged) Persistent advantage for Mauritius
Dividends 5-15% withholding 5-15% depending on shareholding 5% if shareholding ≥ 10%
Interest Variable 7.5% maximum Reduced vs Indian domestic rate (20%)
Royalties Variable 15% maximum Reduced vs Indian domestic rate (20%)
Technical fees Variable 10% maximum Applicable to management services

Persistent advantages of the treaty

Investments in bonds and debt

Capital gains on debt instruments (government bonds, corporate bonds, NCDs) remain exempt from tax in India when realised via a Mauritian GBC. This is a unique advantage that Singapore, Hong Kong or Luxembourg cannot offer. For India-focused bond funds, Mauritius is the jurisdiction of choice.

Reduced withholding tax rates

Dividends at 5-15% (vs 20% domestic), interest at 7.5% (vs 20% domestic), royalties at 15% (vs 20% domestic). These significant reductions apply automatically when the GBC presents a valid TRC to the Indian withholder. Substantial savings for recurring flows.

Effective rate of 3% in Mauritius

Indian income (dividends, interest, royalties, fees) received by a Mauritian GBC is taxed at only 3% in Mauritius via the DFTC. Combined with the reduced treaty rates in India, the total tax burden is significantly lower than that of a direct structure or one via a jurisdiction without a DFTC.

Investment protection

The Mauritius-India BIT offers bilateral legal protection to investors: fair and equitable treatment, protection against expropriation, free transfer of funds and access to international arbitration. This legal safety net is valuable in a sometimes unpredictable Indian regulatory environment.

Essential condition — Substance: Since the 2016 revision, India applies a reinforced Limitation of Benefits (LOB) clause. To benefit from the treaty, the Mauritian GBC must demonstrate minimum annual expenditure of Rs 1.5 million (~USD 33,000) in Mauritius and must not be a shell or conduit company. Genuine economic substance (office, staff, management decisions taken in Mauritius) is essential to invoke the treaty's benefits against the Indian tax administration.

CECPA: a new commercial horizon

The Comprehensive Economic Cooperation and Partnership Agreement (CECPA), signed in February 2021 and entered into force in April 2021, is a historic free trade agreement between Mauritius and India. It is the first agreement of its kind between India and an African country, giving Mauritius a unique competitive advantage.

Scope of the agreement

Area Content Benefits for businesses based in Mauritius
Trade in goods Preferential access for 310 Mauritian products Exports to India with reduced or eliminated customs duties (textiles, sugar, processed foods, jewellery)
Trade in services Liberalisation across 115 services sectors Access to the Indian market for IT, financial, healthcare, education, tourism and professional services
Investment Protection and promotion of bilateral investment Reinforced framework for FDI in both directions, complementary to the existing BIT
Movement of persons Facilitation of professional travel Easier work visas for Mauritian professionals in India and vice versa
Intellectual property Reinforced protection framework (TRIPS+) Enhanced protection for trademarks, patents and copyrights in both jurisdictions
Rules of origin Substantial transformation criteria Ability to benefit from preferences for products manufactured or processed in Mauritius

Unique competitive advantage: CECPA positions Mauritius as the only African jurisdiction with a comprehensive free trade agreement with India. No competing financial centre (Singapore, Hong Kong, Dubai, Luxembourg) has such combined access to African markets (SADC, COMESA) AND the Indian market via an FTA. For businesses wishing to operate simultaneously in Africa and India, Mauritius is without equivalent.

Tax treaties with Asia

Beyond India, Mauritius has a network of tax treaties covering the main Asian economies, allowing investments to be structured across the region with reduced withholding taxes.

Country Dividends Interest Royalties Notes
India 5-15% 7.5% 15% CECPA in force, active LOB clause
China 5% 10% 10% Jin Fei Special Economic Zone in Mauritius
Singapore 0% 0% 0% Very favourable treaty, synergies between IFCs
Malaysia 5-15% 15% 15% Access to the ASEAN market via Kuala Lumpur
Thailand 10% 10-15% 5-15% ASEAN manufacturing and tourism hub
Sri Lanka 5-15% 10% 10% Geographic and cultural proximity
Bangladesh 10% 10% 10% Fast-growing emerging economy
Vietnam Variable Variable Variable Booming manufacturing economy
Pakistan 10% 10% 10-15% Market of 220 million people
Nepal 5-10% 10-15% 15% Emerging South Asian economy

Structuring investments in India via Mauritius

Investments in India structured via Mauritius mainly take three forms, each with its own characteristics.

Foreign Portfolio Investment (FPI)

Process

Creation of a GBC in Mauritius, registration with SEBI (Securities and Exchange Board of India) as an FPI Category I or II via a Designated Depository Participant (DDP). The GBC obtains an Indian PAN (Permanent Account Number) and opens a depository account with an Indian custodian (CDSL or NSDL).

Advantages

Access to the BSE and NSE markets (equities, bonds, derivatives). CGT exemption in India on bonds via the treaty. Reduced withholding on dividends (5-15%). Effective tax rate of 3% in Mauritius on Indian income. Administration and compliance handled from Mauritius by the Management Company.

Foreign Direct Investment (FDI)

  1. Creation of the holding GBC

    Incorporation of a GBC in Mauritius with an FSC licence. Capitalisation via investor contributions. Appointment of qualified resident directors. Obtaining the TRC from the MRA. The GBC must have genuine economic substance (office, staff, annual expenditure ≥ Rs 1.5M).

  2. Investment in India

    Subscription to the capital of an Indian company (new or existing). Compliance with RBI (Reserve Bank of India) rules on FDI: permitted sectors, shareholding caps, automatic route or prior approval. Mandatory RBI reporting (FC-GPR, FC-TRS).

  3. Management and repatriation

    Receipt of dividends with reduced withholding (5-15% vs 20% domestic). Interest on intercompany loans (ECB) with 7.5% withholding. Royalties and management fees with reduced withholding. All this income is taxed at 3% in Mauritius via the DFTC.

  4. Exit

    Disposal of the Indian shareholding. Since 2016, capital gains on shares are taxable in India (Indian CGT applies). Capital gains on debt/bonds remain exempt in India via the treaty. The proceeds of disposal are repatriated to Mauritius and then distributed to investors with 0% withholding.

India-focused investment funds

Many funds targeting India are domiciled in Mauritius under an FSC licence, making the island a preferred platform for fund structuring. The most common structures:

India-focused private equity

Closed-End Fund or Limited Partnership in Mauritius investing in growing Indian companies (mid-market, growth capital, buyout). Typical duration of 8-10 years with extensions. Classic GP/LP structure with carried interest. Mauritian Management Company handling administration.

Venture capital

Financing of Indian startups in fintech, healthtech, edtech, SaaS, e-commerce and deep tech. Possible registration as a SEBI Alternative Investment Fund (AIF) Category I or via the FPI route. The Indian VC scene is one of the most dynamic in the world.

Bond and debt funds

Investment in Indian government bonds (G-Secs), corporate bonds and NCDs (Non-Convertible Debentures). Key advantage: capital gains remain exempt in India via the treaty. The Indian bond market is one of the largest in Asia with attractive yields.

Real estate and infrastructure

Funds investing in Indian commercial and residential real estate, infrastructure projects (roads, energy, ports) and listed REITs/InvITs. The Indian real estate sector represents a market of USD 200+ billion with sustained growth.

Mauritius and Southeast Asia

Beyond India, Mauritius is actively developing its ties with Southeast Asia and East Asia, positioning itself as a bridge between Africa and Asia.

China

Tax treaty with 5% withholding on dividends. Jin Fei Special Economic Zone in Mauritius, developed by a Chinese consortium. Growing trade links under the Belt and Road Initiative (BRI). Chinese investments in Africa structured via Mauritius.

Singapore

Very favourable tax treaty (0% withholding on dividends, interest and royalties). Natural synergies between the two financial centres: Mauritius for Africa, Singapore for ASEAN. Combined Mauritius + Singapore structures for pan-Africa/Asia groups.

ASEAN

Mauritius as a bridge between Africa and ASEAN via treaties with Malaysia, Thailand and Vietnam. South-South trade and investment opportunities. The Mauritius-India CECPA indirectly opens doors to the Indian trade ecosystem connected to ASEAN (RCEP).

Look East Policy

The Mauritian government's "Look East" policy aims to strengthen economic ties with Asia. This includes negotiating new tax treaties, developing trade corridors and attracting Asian investment into Mauritius and into Africa via Mauritius.

Our expertise in Asian investments

Our team has deep expertise in structuring investments into India and Asia via Mauritius, covering the entire investment cycle.

  • FPI/FDI structuring — Creation of GBCs to invest in India, obtaining TRCs, establishing the required substance
  • SEBI registration — Full assistance with registration as an FPI (Category I/II) with the Indian regulator via a DDP
  • India-focused funds — Structuring of CIS and CEF targeting Indian markets (equity, debt, real estate, infrastructure)
  • LOB compliance — Establishing and maintaining the economic substance required to satisfy the limitation of benefits clause
  • CECPA optimisation — Advice on using CECPA benefits for trade in goods and services with India
  • China/ASEAN structures — Using treaties with China, Singapore and Malaysia for investments in Southeast Asia

Invest in India and Asia via Mauritius

Mauritius remains the leading platform for investments in India and Asia, combining significant tax benefits, treaty access and the unique CECPA agreement. Contact our experts to design your Asian investment strategy.

Contact us

Invest in India and Asia via Mauritius

Mauritius remains the leading platform for investments in India and Asia, combining significant tax benefits, treaty access and the unique CECPA agreement.

Request a Free Consultation

Frequently Asked Questions

Why is Mauritius historically linked to India?

The ties between Mauritius and India run deep: around 68% of the Mauritian population is of Indian origin (descendants of indentured labourers who arrived after the abolition of slavery in 1835), Hindi, Bhojpuri and other Indian languages are spoken, and the two countries have maintained close diplomatic and trade relations since 1948. The 1982 tax treaty made Mauritius the top foreign investor in India for nearly 40 years.

Is the Mauritius-India tax treaty still advantageous after the 2016 revision?

The treaty was revised in 2016 to allow India to tax capital gains on Indian shares (source-based taxation). However, the treaty continues to offer significant benefits: capital gains on bonds and debt instruments remain exempt in India, dividend withholding is reduced to 5-15%, interest to 7.5%, and the effective tax rate in Mauritius remains 3% via the DFTC.

Is Mauritius still competitive against Singapore for investing in India?

Yes. Since 2016, the India-Mauritius and India-Singapore treaties have been aligned for capital gains on shares. But Mauritius retains advantages: an effective corporate tax rate of 3% (vs 17% in Singapore), operating costs 60-70% lower, a persistent advantage on bonds/debt, and CECPA offers unique trade access. For investments in Indian debt, Mauritius remains the jurisdiction of choice.

What types of Indian investments are structured via Mauritius?

The main types are: portfolio investments (FPI) in equity and bond markets (BSE, NSE), direct investments (FDI) in Indian companies via GBC holding companies, private equity and venture capital funds targeting India, joint ventures between Indian and international companies, and financing structures (ECB — External Commercial Borrowings).

Does Mauritius have tax treaties with other Asian countries?

Yes, Mauritius has treaties with 10+ Asian countries: India, China, Singapore, Malaysia, Thailand, Sri Lanka, Bangladesh, Nepal, Pakistan and Vietnam. This network makes Mauritius an effective hub for investments across the entire Asia-Pacific region, with reduced withholding tax rates on dividends, interest and royalties.

Does the Mauritius-India CECPA change the picture for trade?

CECPA (the Comprehensive Economic Cooperation and Partnership Agreement), signed in 2021, is India's first free trade agreement with an African country. It offers preferential market access to India for 310 Mauritian products, liberalisation of 115 services sectors (IT, finance, healthcare), and investment provisions. It is a competitive advantage that neither Singapore, Hong Kong nor Dubai possesses.

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