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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Mauritius: double taxation agreement, Article 22: Income not expressly mentioned

  1. Subject to the provisions of paragraphs (2) and (3) of this Article items of income of a resident of a Contracting State, wherever arising, being income of a class or from sources not expressly mentioned in the foregoing Articles of this Convention in respect of which he is subject to tax in that State, shall be taxable only in that State.
  2. The provisions of paragraph (1) of this Article shall not apply if the person deriving the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or 14, as the case may be, shall apply.
  3. The provisions of paragraph (1) of this Article shall not apply to income paid out of trusts.