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Direct action

In fact I see this as providing more opportunities for Mauritius. The treaty override in the DTC while significant is limited in scope to cinstances when the GAAR, CFC and branch profit tax rules are invoked. India will be careful in not giving free rein to its GAAR provisions. Ultimately this will mean that investors will have to give more substance to the Mauritius entities, which would create more employment in Mauritius. Mauritians are a very able workforce- they speak fluent french and english. Many Mauritian professionals work in magic circle firms and investment banks and many of them do go back to Mauritius. There is a pool of talent here.

11-Nov-2010

4:35 pm