Nikhel Ramgobin

Mauritius’ Supreme Court clarifies the Foreign Tax Credit (“FTC”) regime in UPL Corporation Ltd v Revenue Tribunal & Anor (2026 SCJ 161).The Court confirmed that the actual foreign tax and the 80% presumed FTC can be combined under the pooling method, while maintaining the cap at Mauritian tax payable. A concise,…

Tax Alert: Carleton Management Ltd v. Director-General, MRA (ARC/IT/505-23) The Revenue Tribunal has clarified the rules on Tax Deduction at Source (TDS): TDS must be claimed in the same year it is deducted. If you claim late, you may lose the credit, even if you are entitled to it. You…

The Supreme Court of India has overturned the Delhi High Court’s ruling in the Tiger Global Mauritius case, marking a significant development in India’s treaty jurisprudence. The judgment reinforces a substance-over-form approach and clarifies that Tax Residency Certificates and grandfathering provisions under the India–Mauritius DTAA do not provide automatic or…