The Mauritius Cabinet’s ratification of a 2024 protocol to its tax treaty with India, introducing the Principal Purpose Test, has sparked investor concerns over broader scrutiny, though experts say it creates no new anti-abuse powers. The protocol to the Double Taxation Avoidance Agreement (DTAA) with India introduces a new anti-abuse provision, raising concerns that Indian tax authorities may gain heightened powers to scrutinise investors from Mauritius. The aim of the protocol is to align the India-Mauritius DTAA, signed in April 1983 and amended by a protocol in May 2016, with global Base Erosion and Profit Shifting (BEPS) anti-abuse provisions. The protocol introduces the Principal Purpose Test (PPT), under which tax authorities can deny treaty benefits where obtaining the tax benefit was one of the main purposes of a transaction.