On 22 May 2015, officials from Mauritius and South African signed a memorandum of understanding concerning the determination of tax residence in cases of dual residence for the purpose of the 2013 tax treaty between the two countries, which is not yet in force.
Under the treaty, if a company is considered a resident of both Contracting States, the competent authorities of both States will determine its residence for the purpose of the treaty through mutual agreement. If no agreement is reach…