6. Tax treaties intended to avoid double taxation have in many cases become instruments for double non-taxation. Elaborate. List the major amendments in the India-Mauritius DTAA and the advantages that are expected to accrue due to it.

Approach:

♤ Briefly explain what is DTAA and its relevance. Substantiate the first statement given in the question.

♤ Now explain the negative spill overs or loopholes in the treaty leading to double non-taxation; a loss to the government.

♤ In light of above consequences, list down the amendments in the tax treaty and its advantages.