Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

Mauritius

Recent developments relating to MAP in Mauritius prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• Following the Stage 1 Simplified Peer Review process, Mauritius is engaging with its concerned tax treaty partners by submitting requests for bilateral negotiations and sending reminders in order to make the tax treaties compliant with the minimum standards of BEPS Action 14.

Other developments relating to MAP

• Following the Stage 1 Simplified Peer Review process, Mauritius is currently working to address the recommendations received in respect of its MAP Guidance Notes and its Standard of Procedures.

Latest Action 14 Peer Review report

The stage 1 Simplified Peer Review report of Mauritius is expected to be published early 2024.

Tax treaty network of Mauritius

• 53 treaties, applicable to 53 jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: in force.

Table 1. State of play of Mauritius's tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
37	9	0

Source: OECD

Mauritius's MAP programme

Organisation of competent authority function

• four persons:

  • one head of unit

  • three persons working on MAP cases.

• contact persons for MAP requests:

  • Mr. Mamade Faisal Oozeerally, Director, [e-mail] Mr. Krishna Rambaksh, Section Head, [e-mail] Large Taxpayers Department & International Taxation Unit, MRA Mauritius Revenue Authority Level 5 Ehram Court Cnr. Sir Virgil Naz & Mgr Gonin Streets Port Louis MAURITIUS.

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	Mutual Agreement Procedure Guidance Notes, November 2020	https://www.mra.mu/download/MAPGuidanceNotes.pdf (Chapter 2 to be referred to for form and content of a MAP request, including information requirements)
MAP profile	23 May 2023	https://www.oecd.org/tax/dispute/mauritius-dispute-resolution-profile.pdf

Overview of Mauritius's MAP Statistics for 2022

Please refer to https://www.oecd.org/tax/dispute/map-statistics-mauritius.pdf for details with respect to Mauritius's MAP Statistics.

Figure 2. Cases closed in 2022

Source: OECD

Figure 3. Evolution of Mauritius's MAP caseload (2016-22)

Source: OECD

Table 3. Overview of Mauritius’s MAP caseload for 2022

Inventory for year 2022	Opening Inventory 1/1/2022	Cases started	Cases Closed	End Inventory 31/12/2022
Attribution/allocation cases	0	0	0	0
Other cases	3	4	1	6
Total	3	4	1	6

Source: OECD

Table 4. Mauritius’s average time to resolve MAP cases in 2022

Cases resolved in year 2022	Pre-2016 cases		Post-2015 cases		All
	Number of cases	Average time	Number of cases	Average time	Number of cases	Average time
				Start to End
Attribution / Allocation cases	0	N/A	0	N/A	0	N/A
Other cases	0	N/A	1	1	1	1
All cases	0	N/A	1	N/A	1	N/A

Source: OECD