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Mauritius Status of List of Reservations and Notifications at the Time of Signature This document contains a provisional list of expected reservations and notifications to be made by the Republic of Mauritius pursuant to Articles 28(7) and 29(4) of the Convention. 1 Article 2 – Interpretation of Terms Notification - Agreements Covered by the Convention Pursuant to Article 2(1)(a)(ii) of the Convention, Mauritius wishes the following agreements to be covered by the Convention: Other Original/ Date of Date of Entry No Title Contracting Amending Signature into Force Jurisdiction Instrument Agreement between the government of therepublic of Mauritius and the government of 1 Barbados for the avoidance of Barbados Original 28-09-2004 28-01-2005 double taxation and the prevention of fiscal evasion with respect to taxes on income Convention between the republic of Mauritius and the kingdom of Belgium for the avoidance of Kingdom of 2 Original 04-07-1995 28-01-1999 double taxation and the prevention Belgium of fiscal evasion with respect to taxes on income CONVENTION ENTRE LE GOUVERNEMENT DE LA RÉPUBLIQUE DE MAURICE ET LE GOUVERNEMENT DE LA Republic of 3 REPUBLIQUE DU CONGO TENDANT Original 20-12-2010 08-10-2014 Congo A ÉVITER LES DOUBLES IMPOSITIONS ET A PRÉVENIR L'ÉVASION FISCALE EN MATIERE D'IMPOTS SUR LE REVENU. Agreement between the Government of the Republic of Mauritius and the Government of Republic of 4 the Republic of Croatia Original 06-09-2002 09-08-2003 Croatia for the avoidance of double taxation with respect to taxes on income AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MAURITIUS AND THE GOVERNMENT OF THE REPUBLIC OF Republic of 5 Original 21-01-2000 12-06-2000 CYPRUS FOR THE AVOIDANCE OF Cyprus DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND CAPITAL 2 CONVENTION BETWEEN MAURITIUS Original 11-12-1980 17-09-1982 AND THE REPUBLIC OF FRANCE For Republic of 6 the Avoidance of Double Taxation France with respect of Taxes on Income Amending and Capital 23-06-2011 01-05-2012 Instrument (a) AGREEMENT BETWEEN THE REPUBLIC OF MAURITIUS AND THE FEDERAL REPUBLIC OF GERMANY Federal 7 FOR THE AVOIDANCE OF DOUBLE Republic of Original 07-10-2011 07-12-2012 TAXATION AND OF TAX EVASION Germany WITH RESPECT TO TAXES ON INCOME AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MAURITIUS AND THE STATES OF GUERNSEY FOR THE AVOIDANCE OF States of 8 Original 17-12-2013 30-06-2014 DOUBLE TAXATION AND THE Guernsey PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME CONVENTION between the Original 09-03-1990 28-04-1995 Government of Mauritius and the Government of the Republic of Italy Republic of 9 for the avoidance of Double Italy Amending Taxation with respect to Taxes on 09-12-2010 19-11-2012 Income and for the Prevention of Instrument (a) Fiscal Evasion AGREEMENT between the Government of the Republic of Mauritius and the Government of the State of Kuwait for the State of 10 Original 24-03-1997 01-09-1998 Avoidance of Double Taxation Kuwait and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital AGREEMENT between the Government of the Republic of Mauritius and the Government of the Kingdom of Kingdom of 11 Original 29-08-1997 09-09-2004 Lesotho for the Avoidance of Lesotho Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income CONVENTION between The Grand Duchy Original 12 15-02-1995 12-09-1996 Government of the Republic of of 3 Mauritius and the Grand Duchy of Luxembourg Luxembourg for the Avoidance of Amending Double Taxation and the Prevention 28-01-2014 11-12-2015 instrument (a) of Fiscal Evasion with Respect to Taxes on Income and on Capital CONVENTION ENTRE LE GOUVERNEMENT DE LA REPUBLIQUE DE MAURICE ET LE GOUVERNEMENT DE LA Republic of 13 REPUBLIQUE DE MADAGASCAR Original 30-08-1994 01-12-1995 Madagascar tendant à éviter les doubles impositions et la prevention de l’évasion fiscale en matière d’impôts sur le revenu. AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MAURITIUS AND THE GOVERNMENT OF THE REPUBLIC OF Republic of Original 14 MALTA FOR THE AVOIDANCE OF 15-10-2014 23-04-2015 Malta DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME CONVENTION ENTRE LA REPUBLIQUE DE MAURICE ET LA PRINCIPAUTE DE MONACO Principaute 15 TENDANT A EVITER LES DOUBLES Original 13-04-2013 08-08-2013 de Monaco IMPOSITIONS ET A PREVENIR L’EVASION FISCALE EN MATIERE D’IMPOTS SUR LE REVENU. AGREEMENT between the Government of the Republic of Mauritius and the Government of Sultanate of 16 the Sultanate of Oman for the Original 30-03-1998 20-07-1998 Oman Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income AGREEMENT BETWEEN THE GOVERNMENT OF THE STATE OF QATAR AND THE GOVERNMENT OF THE REPUBLIC OF MAURITIUS FOR State of 17 Original 28-07-2008 28-07-2009 THE AVOIDANCE OF DOUBLE Qatar TAXATION AND THE PREVENTION OF IFSCAL EVASION WITH RESPECT TO TAXES ON INCOME AGREEMENT BETWEEN THE Republic of 18 GOVERNMENT OF THE REPUBLIC OF Original 28-09-2004 28-01-2005 Seychelles MAURITIUS AND THE 4 GOVERNMENT OF THE REPUBLIC OF SEYCHELLES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE Amending 03-03-2011 18-05-2012 PREVENTION OF FISCAL EVASION instrument (a) WITH RESPECT TO TAXES ON INCOME AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE REPUBLIC OF Republic of Original 19 MAURITIUS FOR THE AVOIDANCE 17-05-2013 28-05-2015 South Africa OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AGREEMENT BETWEEN THE GOVERNMENT OF THE KINGDOM OF SWAZILAND AND THE GOVERNMENT OF THE REPUBLIC OF Kingdom of 20 MAURITIUS FOR THE AVOIDANCE Original 29-06-1994 08-11-1994 Swaziland OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME. CONVENTION BETWEEN THE REPUBLIC OF MAURITIUS AND THE KINGDOM OF SWEDEN FOR THE Kingdom of 21 AVOIDANCE OF DOUBLE TAXATION Original 01-12-2011 07-12-2012 Sweden AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MAURITIUS AND THE GOVERNMENT OF THE UNITED United Arab 22 Original 18-09-2006 31-07-2007 ARAB EMIRATED FOR THE Emirates AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME CONVENTION BETWEEN THE Original 11-02-1981 19-10-1981 GOVERNMENT OF MAURITIUS AND Amending 23-10-1986 26-10-1987 THE GOVERNMENT OF THE UNITED The United Instrument (a) KINGDOM OF GREAT BRITAIN AND Kingdom of Amending 27-03-2003 23-10-2003 23 NORTHERN IRELAND For the Great Britain Instrument (b) Avoidance of Double Taxation and and Northern the Prevention of Fiscal Evasion Ireland Amending 10-01-2011 13-10-2011 with respect to Taxes on Income Instrument (c) and Capital Gains 5 Article 3 – Transparent Entities Reservation Pursuant to Article 3(5)(a) of the Convention, Mauritius reserves the right for the entirety of Article 3 not to apply to its Covered Tax Agreements. Article 4 – Dual Resident Entities Reservation Pursuant to Article 4(3)(a) of the Convention, Mauritius reserves the right for the entirety of Article 4 not to apply to its Covered Tax Agreements. Article 5 – Application of Methods for Elimination of Double Taxation Reservation Pursuant to Article 5(8) of the Convention, Mauritius reserves the right for the entirety of Article 5 not to apply with respect to all of its Covered Tax Agreements. Article 6 – Purpose of a Covered Tax Agreement Notification of Choice of Optional Provisions Pursuant to Article 6(6) of the Convention, Mauritius hereby chooses to apply Article 6(3). Notification of Existing Preamble Language in Listed Agreements Pursuant to Article 6(5) of the Convention, Mauritius considers that the following agreements are not within the scope of a reservation under Article 6(4) and contain preamble language described in Article 6(2). The text of the relevant preambular paragraph is identified below. Listed Other Agreement Contracting Preamble Text Number Jurisdiction Desiring to conclude an Agreement for the avoidance of 1 Barbados double taxation and the prevention of fiscal evasion with respect to taxes on income, Desiring to conclude a Convention for the avoidance of double Kingdom of 2 taxation and the prevention of fiscal evasion with respect to Belgium taxes on income, Désireux de conclure une Convention en vue d’éviter les Republic of 3 doubles impositions et de prévenir l'évasion fiscale en matière Congo d'impôts sur le revenu, Republic of Desiring to conclude an Agreement for the avoidance of 4 Croatia double taxation with respect to taxes on income, 5 Republic of Desiring to conclude an Agreement for the avoidance of 6 Cyprus double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, Republic of Desiring to conclude a Convention for the avoidance of double 6 France taxation with respect to taxes on income and on capital Federal Desiring to conclude an Agreement for the avoidance of 7 Republic of double taxation and of tax evasion with respect to taxes on Germany income, Desiring to conclude an Agreement for the avoidance of States of 8 double taxation and the prevention of fiscal evasion with Guernsey respect to taxes on income, Desiring to conclude a Convention for the avoidance of double Republic of 9 taxation with respect to taxes on income and for the Italy prevention of fiscal evasion, desiring to <promote their mutual economic relations by removing fiscal obstacles through the>conclusion of an 10 State of Kuwait agreement for the avoidance