Mra Double Taxation Agreements For any signatory ratifying the MLI after the deposit of the fifth instrument of ratification, the MLI shall enter into force on the first day of the month following the expiration of a period of three calendar months, from the date of deposit of its instrument of ratification by that signatory with the OECD. Thus, Australia deposited its instrument of ratification with the OECD on 26 September 2018: the MLI for Australia entered into force on 1 January 2019. An updated version of the OECD Model Agreement on Income and Capital (OECD ERM 2017) was published in November 2017. The OECD`s ERM 2017 contains significant changes that are a direct result of the OECD/G20 BEPS project. Article 26 of the Tax Convention with Sweden contains a limitation of benefit (LOB) clause, which applies by way of application where a company mainly earns income from certain activities and, under the law of the State of residence, that income has a tax significantly lower than that of activities carried on in that State. An established corporation is not taxable. Instead, each partner of the Company is required to tax their share of the income, whether distributed or not. The Financial Services Act has been amended to require foreign-controlled companies to apply for a Global Business Licence (GBL) when operating primarily outside Mauritius. On 23 January 2019, the Financial Services Commission (FSC) announced, in the meantime, through the Global Business Corporations Rules, that a GBL was required for a company established in Mauritius on 31 December 2018 or before 31 December 2018 and which held neither GBL1 nor GBL2. before December 31, 2018. A mauritius-based company that does not hold a GBL is welcome, as it is taxed on Residents of The Mauricie under general tax legislation and is not entitled to tax incentives. In addition, the MRA may ask the chamber judge to require the taxpayer to comply with the request for information (amendment of the Finance Law 2019). .

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