How Mauritius Tax Protocol Could Give India Powers To Probe Offshore Investments
Published on: Wednesday 22 July 2026
Mauritius' decision to ratify the 2024 protocol amending its Double Taxation Avoidance Agreement (DTAA) with India could significantly strengthen India's ability to scrutinise offshore investment structures that are suspected of being created primarily to obtain tax benefits. While the protocol has not yet entered into force, it introduces a key anti-abuse provision known as the Principal Purpose Test (PPT), allowing tax authorities to deny treaty benefits where tax avoidance is considered one of the main objectives of an arrangement. The change could give Indian tax officials greater powers to directly question offshore entities claiming benefits under the India-Mauritius tax treaty, as per a report by The Economic Times (ET).
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