ARTICLE · 19 DECEMBER 2024

Mauritius Transfer Pricing Case: A New Challenge For Multinationals

Fairbridges

In recent years, transfer pricing has become a critical issue for multinational corporations (MNCs), especially those involved in the commercialisation of intellectual property (IP).

MauritiusTax

Gaby Meintjes

Author LinkedIn connections

In recent years, transfer pricing has become a critical issue for multinational corporations (MNCs), especially those involved in the commercialisation of intellectual property (IP). The recent case of Avago Technologies Trading Ltd v/s Mauritius Revenue Authority (MRA) marks a significant development in the application of transfer pricing rules in lower tax jurisdictions like Mauritius. This case highlights the evolving landscape of international tax compliance and the increasing scrutiny faced by MNCs in managing their global operations.

On 04 July 2024, the Assessment Review Committee (ARC) delivered a ruling in favour of the MRA, focusing on the arm's length nature of royalty fees paid by Avago Technologies Trading Ltd (ATTL) to its related entity, GEN IP, based in Singapore. ATTL, a Global Business Company in Mauritius, operates in the semiconductor industry and holds a portfolio of IP products under a License Agreement with GEN IP. This agreement allowed ATTL

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Mauritius Transfer Pricing Case: A New Challenge For Multinationals

Related Articles

Mauritius Cabinet Approves Pending Protocol To Tax Treaty With India

Landmark Mauritian Judgment From The Judicial Committee Of The Privy Council

The Privy Council Provides Clarity To The Global Business Industry: Interest Exemptions Upheld In Mauritius

Mauritius National Budget 2026-27

POEM And CMC: Not The Same — And Mauritius, As It Happens, Provides The Answer

Read more about

Related Comparative Guides

Tax

Tax Disputes

See more popular content from

Mauritius Cabinet Approves Pending Protocol To Tax Treaty With India

Mauritius National Budget 2026-27

Corporate Tax Comparative Guide

Tax Ruling By The Mauritian Revenue Authority On Chargeable Interest Income

Mauritius Is Changing Its Tax Rules In A Significant Way

Mauritius Supreme Court Rules On Eligibility To Claim Partial Exemption

Fundamental Changes To The India Mauritius Double Tax Treaty Announced

The Privy Council Provides Clarity To The Global Business Industry: Interest Exemptions Upheld In Mauritius

Encouraging Investment

POEM And CMC: Not The Same — And Mauritius, As It Happens, Provides The Answer

Understanding FIFA's Third-party Non-interference Principle

Transferring Immovable Property From A Deceased Estate: Understanding The Process

How To Check Your Property Zoning And Apply For Changes In Cape Town

Restrictions On Agricultural Land Transactions: Key Considerations For Farm Buyers

Estate Duty Planning Between Spouses

Guarantee Or Suretyship?

Trading Property For Shares: A Strategic Way To Move Assets Into A Company

Can A Verbal Agreement Really Hold Up In Court?

Buying Property In South Africa While Living Abroad: How Exchange Control Shapes Your Mortgage

What The New Expropriation Act Means For Landowners And Reform In South Africa