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Treasure Island: Leak Reveals How Mauritius Siphons Tax From Poor Nations to Benefit Elites

Based on 200,000 files, Mauritius Leaks exposes a sophisticated system that diverts tax revenue from poor nations back to the coffers of Western corporations and African oligarchs.

Bob Geldof’s firm wanted to buy a chicken farm in Uganda, one of the poorest countries on earth. But first, an errand.

After soaring to fame in the 1980s for organizing Live Aid and other anti-famine efforts, the former Boomtown Rats rocker had shifted to the high-powered world of international finance. He founded a U.K.-based private equity firm that aimed to generate a 20% return by buying stakes in African businesses, according to a memorandum from an investor.

The fund’s investments would all be on the African continent. Yet its London-based legal advisers asked that one of its headquarters be set up more than 2,000 miles away on Mauritius, according to a new trove of leaked documents.

The tiny Indian Ocean island has become a destination for the rich and powerful to avoid taxes with discretion and a financial powerhouse in its own right.

One of the discussion points in the firm’s decision: “tax reasons,” according to the email sent from London lawyers to Mauritius.

Geldof’s investment firm won Mauritius government approval to take advantage of obscure international agreements that allow companies to pay rock-bottom tax rates on the island tax haven and less to the desperately poor African nations where the companies do business.

Tax issues raised in 8 Mile Mauritius Leaks email
8 Mile’s advisers raised tax issues in a number of emails in the Mauritius Leaks documents.

“One little wad of cash can be the difference between a poor country building big infrastructure or not,” a Ugandan tax official told ICIJ.

Another benefit of a headquarters on Mauritius: opacity. Transactions to and from Mauritius to local units – that can have huge impacts on tax liability – are tucked away in confidential financial reports filed on the island.

A spokesman for Geldof’s firm, 8 Miles LLP, said its investors include international development finance institutions that “request that we consolidate their funds in a safe African financial jurisdiction for onward investment into the various target African countries. Because of its reputation, Mauritius is used by many private equity investors for this purpose.”

The spokesman said the firm’s African investments follow high standards “to create jobs, improve communities…and by generating increasing tax revenues which support the governments where we operate.”  The spokesman said, “Only when we sell a company will the sale proceeds be paid back into the fund in Mauritius.”

Geldof declined to comment.

Mauritius Leaks, a new investigation by the International Consortium of Investigative Journalists and 54 journalists from 18 countries, provides an inside look at how the former French colony has transformed itself into a thriving financial center, at least partly at the expense of its African neighbors and other less-developed countries. In Uganda, more than 40% of the population lives on less than $2 a day.

Based on a cache of 200,000 confidential records from the Mauritius office of the Bermuda-based offshore law firm Conyers Dill & Pearman, the investigation reveals how a sophisticated financial system based on the island is designed to divert tax revenue from poor nations back to the coffers of Western corporations and African oligarchs, with Mauritius getting a share. The files date from the early 1990s to 2017.

The island, which sells itself as a “gateway” for corporations to the developing world, has two main selling points: bargain-basement tax rates and, crucially, a battery of “tax treaties” with 46 mostly poorer countries. Pushed by Western financial institutions in the 1990s, the treaties have proved a boon for Western corporations, their legal and financial advisers, and Mauritius itself — and a disaster for most of the countries that are its treaty partners.

“What Mauritius is providing is not a gateway but a getaway car for unscrupulous corporations dodging their tax obligations,” said Alvin Mosioma, executive director of the nonprofit Tax Justice Network Africa.

The leaked records – including emails, contracts, meeting notes and audio recordings – provide a glimpse inside a busy offshore law firm working with global accounting and advisory firms for some of the world’s largest corporations and some very wealthy individuals.

They’ve all found their way to an island built on helping the rich avoid paying taxes to nations as far-flung as the United States, Thailand, and Oman.

Mauritius’ minister of financial services of good governance Dharmendar Sesungkur, who oversees the country’s offshore sector, said that ICIJ’s information was “outdated.” The minister said that independent organizations, including the World Bank, recognize that “Mauritius is a cooperative and clean jurisdiction that has made significant progress in adhering to international standards.” [Read the Government of Mauritius’ full response]

Mauritius has introduced “major policy (as well as legislative) changes,” Sesungkur said. Prime Minister Pravind K Jugnauth recently announced tighter rules for companies that want to benefit from the island’s low tax rates; such companies must have greater control and activity in Mauritius and more skilled employees.

Pampering elites in the Persian Gulf

In 2012, American philanthropist Craig Cogut and his multibillion-dollar private equity firm, Pegasus Capital Advisors, looked 9,217 miles from the firm’s home base in Stamford, Conn., for a place to locate the management headquarters of one of its new investments. What unfolded is a textbook case of the way businesses can prosper by using Mauritius’ offshore tools.

A Pegasus fund had bought Six Senses, a luxury spa and hotel brand with more than 30 operations on four continents. Frequented by Hollywood stars and other global glitterati, Six Senses drips in luxury. Villas on private islands in the Seychelles, off East Africa, cost as much as $15,000 a night. The Al Bustan Palace spa in Oman, one of the less affluent countries on the Arabian Peninsula, offers private men- and women-only beaches and personalized face scrubs made with locally grown clove and myrrh.

The Six Senses brand, which promotes “caring for hosts [employees] and local communities” in marketing materials, was a natural addition to Pegasus’ portfolio. The firm, with $1.5 billion under management, invests in socially conscious companies that, among other things, recycle food waste and create drugs to treat diarrhea in disadvantaged children. “We care not just about impact alone, but making a ‘net-positive’ impact,” Cogut wrote in 2018.

In May 2012, Pegasus created a company, Sustainable Luxury Mauritius Ltd., with a post office box in the Ebene, the island’s technology hub. The new company was owned by a British Virgin Islands corporation that Cogut owned personally, according to documents.

Sustainable Luxury, which had no employees, received management income and fees for the use of the Six Senses logo at hotels and spas around the world, including two Six Senses operations in Oman, according to contracts that passed through the law firm Conyers.

Six Senses luxury hotel
Six Senses, a luxury spa and hotel brand, has more than 30 operations on four continents.

As a “resident” firm of Mauritius, Sustainable Luxury could take advantage of the country’s super-low, effective maximum corporate tax rate: 3%. Sustainable Luxury also applied for — and received — special legal status from the government of Mauritius, allowing it to benefit from tax treaties between Mauritius and countries where Six Senses had spas and hotels. Treaties allow companies to reduce or entirely avoid common taxes received on cross-border payments, including interest, dividends and royalties.

Sustainable Luxury listed Oman among 11 countries where the company had investments and wished to apply for a special status and document issued by the government of Mauritius, according to company board meeting minutes. That document would allow the company to cut taxes paid to countries around the world that signed treaties with Mauritius. The leaked files don’t say whether the company ever received the document.

Linda Ambrosie, a researcher at the University of Calgary in Alberta, told ICIJ that shunting money through tax havens to avoid local taxes doesn’t square with the idea of “care for hosts and local communities” mentioned in corporate literature.

“Sustainable? Pffff,” scoffed Ambrosie, author of “Sun and Sea Tourism: Fantasy and Finance of the All-Inclusive Industry,” a study of how cruise ships and the multinational travel and resort industry in the Caribbean avoid taxes while exaggerating their contributions to employment, public revenue and environmental protection.

“Sustainably is, first and foremost, a tax issue,” she said, “because whatever you try to do to make a destination more sustainable, like providing fresh water or good roads, needs taxes to pay for it.”

Pegasus and Cogut did not respond to requests for comment.

From sugarcane to shell companies

A longtime possession of the Dutch, French and then the British, Mauritius was for centuries a poor agrarian society with an economy based mostly on sugarcane. Its economic prospects seemed forever limited by its location, 1,250 miles east of the African coast, and tiny size, smaller than Rhode Island.

Then in the early 1990s, Rama Sithanen pushed an idea.

The Mauritius finance minister at the time, Sithanen observed that Luxembourg, Switzerland, Hong Kong and other, more obscure jurisdictions had grown into financial powerhouses by serving as low-tax gateways to wealthy nations nearby. He said Mauritius should do something similar, offering itself as a stable, corruption-free bridge to Africa and other less developed regions.

“The potential exists to explore new avenues and to look for new markets,” he argued before the Mauritius Parliament in 1992, pushing a bill that would make possible the island’s first shell companies and allow some firms to pay zero taxes on profits and capital gains. One parliamentary colleague called the bill “a wonderful tax tool.”

An opposition member objected, saying the bill would create at least the appearance that Mauritius was benefiting at the expense of poorer neighbors.

“It is a tough world,” retorted another government minister in support of the law. “We cannot waste time.”

Within weeks of the bill’s passage, Mauritius officials were off on marketing trips to Asia. In the law’s first year, 10 offshore companies incorporated in Mauritius. Two years later, that number had passed 2,400.

Tax treaties proliferate

A key part of the island’s strategy: tax treaties, lots of them.

Starting back in the 1920s, “double taxation agreements” were adopted to protect businesses with international operations from being taxed twice for the same transaction. Two nations simply agreed on dividing one set of taxes between them. To encourage investment, tax treaties also limited the tax rate governments could apply to certain cross-border transactions.

Tax treaties surged as global trade blossomed after World War II; a second wave came during decolonizations in the 1960s and 1970s. Under the umbrella of the Western-dominated Organization for Economic Cooperation and Development, richer countries pushed for treaties that awarded most of the tax revenue to themselves, not the poorer countries where the business activity took place.

Officials in some developing countries sensed early on that the system was tilted against them. Among their complaints: Western companies were shifting income out of developing countries by inflating “expenses” and “fees” paid to the home office, reducing local taxable income. “They have taken out of Zambia every ngwee [penny]” owed in taxes, Zambian President Kenneth Kaunda fumed in 1973.

Developing countries believed they had to enter into treaties to attract foreign investment, even if it meant signing away tax revenue that could fund education, health care and other vital government services.

Many experts say that treaties often aren’t even necessary. Western governments can, and often do, solve the double taxation problem by granting credits or other relief to domestic companies with overseas operations.

Aid from poor to rich

By 1974, an academic paper was already warning that the treaties in effect represented “aid in reverse – from poor to rich countries.”

Nonetheless, the number of treaties surged again in the 1990s as Western corporations and their advocates within international institutions pushed them as a requirement for attracting foreign investment. Meanwhile, tax havens, seeing an opportunity, dropped their tax rates, encouraged corporations to set up shell “headquarters” in their countries, and promoted tax treaties as a way to avoid paying taxes.

People didn’t even know where Mauritius was located. People mixed things up between Mauritius, Maldives, Malta . . . a lot of small islands starting with the letter ‘M.’ – Nishith Desai

For Mauritius, a big breakthrough came in the early 1990s when an enterprising lawyer in Mumbai discovered that a then-dormant 1982 India-Mauritius tax treaty would allow his Western clients to avoid paying taxes in both the United States and India. Western money poured into the newly liberalized Indian market – after first passing through Mauritius.

“Success has many fathers,” said the lawyer, Nishith Desai, in an interview with ICIJ. “People didn’t even know where Mauritius was located. People mixed things up between Mauritius, Maldives, Malta . . . a lot of small islands starting with the letter ‘M.’ ”

Gushing press releases and news articles suggested that Mauritius was on a path to becoming the Hong Kong or Singapore of the Indian Ocean. “We avoid stacks of tax,” one fund manager told Toronto’s Financial Post in 1994.

Mauritius introduced a flat corporate income tax rate of 15% with foreign tax credits that can drive that down to an effective rate of 3%. Mauritius rolled out Global Business Licence 1, which allows companies with operations elsewhere to be “resident” in Mauritius for tax purposes and pay its low rates. It went on to sign dozens of tax treaties with countries around the world, including 15 in sub-Saharan Africa.

Lately, tax treaties have begun to fall out of favor. A growing chorus of government officials, academics and international institutions have concluded that the treaties are responsible for siphoning vital tax revenue from the world’s poorest nations and are a key driver of global wealth inequality.

Research on 28 treaties signed with the Netherlands found that they cost poorer countries collectively at least $1 billion a year in lost tax revenue, and probably much more. Another study found that 40 treaties Belgium signed with former African colonies and other countries cost them a total of $44 million in 2012, while providing only modest increases in investment. Studies of Austria, Finland, Switzerland and Denmark also showed that treaties exacerbated tax avoidance in poorer countries.

By 2013, almost half of all foreign investment in India could be traced to companies in Mauritius, according to the United Nations. Under its treaty, India had granted Mauritius the sole right to tax capital gains when a Mauritius company sold shares in an Indian company.

The problem? Mauritius doesn’t tax capital gains, meaning companies avoid such taxes in both countries.

In a 2018 study, Tsilly Dagan, an Israeli law professor, flatly called the common justification for tax treaties “a myth.” “Developing countries … have to sacrifice more to become members of the ‘treaty club.’”

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Poorer countries push back

Some countries have tried fighting back – but it’s not easy. Renegotiations can take years. Political leaders often seek to avoid the diplomatic fallout.

South Africa signed a new treaty with Mauritius, which first ignored South Africa’s requests to modify the 1997 text and then resisted for years, according to people involved. Western corporations lobbied the South African parliament to reject the renegotiation and threatened to move their offshore operations to Dubai. The new treaty took effect in 2015.

“The old treaty basically gave the store away,” said Lutando Mvovo, a former South African treasury official who took part in the negotiations.

Successive Indian governments for years challenged the legality of the Mauritius 1982 treaty. And they kept losing. In a landmark 2012 case, India’s Supreme Court held that the tax office could not question U.K. telecom giant Vodafone’s $11 billion acquisition of an Indian rival through a Mauritius company. The decision cost India $2.2 billion in lost tax revenue.

It took 20 rounds of negotiations over 20 years for India to prod Mauritius in 2016 to remove the abusive provisions of the original 1982 treaty, one Indian official told ICIJ.

In separate interviews with ICIJ, tax officials in Egypt, Senegal, Uganda, Lesotho, South Africa, Zimbabwe, Thailand, India, Tunisia and Zambia all said their treaties with Mauritius were crippling.

“Personally, we regret signing the treaty,” said Setsoto Ranthocha, an official with the Lesotho Revenue Authority, now involved in a renegotiation effort. Lesotho’s treaty with Mauritius dates to 1997.

“The companies are the winners,” Ranthocha said. “It makes me go mad.”

Namibia is reviewing its treaty with Mauritius, officials told ICIJ partner The Namibian. In March, Kenya’s high court struck down that country’s treaty with Mauritius for technical reasons. Tax Justice Network Africa filed the complaint, arguing that the treaty would allow companies to abusively “siphon” money out of Kenya. In June, Senegal announced that it would seek to cancel its tax treaty with Mauritius, claiming that the agreement cost it $257 million over 17 years.

“It is the most unequal treaty for Senegal of all the treaties we have signed,” Magueye Boye, a tax inspector and Senegal’s lead treaty negotiator, told ICIJ. It is an “enormous pipeline for tax avoidance,” he said.

Another country reviewing its treaty with Mauritius is Uganda.

Bob Geldof in Africa

Bob Geldof
Anti-poverty campaigner and 8 Mile investment firm founder Bob Geldof. Image: Artur Widak/NurPhoto via Getty Images

In July 1984, Geldof witnessed the famine then devastating Ethiopia and returned home to co-write the song “Do They Know It’s Christmas?” He persuaded Phil Collins, Boy George, Bono and more than a dozen other rock stars to record it, creating one of the best-selling hits of all time. “And in our world of plenty, we can spread a smile of joy,” they sang.

In 1985, Geldof launched the Live Aid concert of top-tier rock stars held in London and Philadelphia that raised more than $140 million for famine relief. He received an honorary knighthood the next year at age 34.

Geldof has continued to speak publicly in support of African economic development. In 2004, he joined then-British Prime Minister Tony Blair to launch an anti-poverty Commission for Africa, singling out Uganda as a particular case of blight and misery.

In a later interview, Geldof discussed the importance of growing small and medium-sized businesses and an expanding middle class on the continent. “Once the state can tax proper income, it can begin to cohere, it can pay its police, its courts, its army,” he said.

In 2008, two decades after Live Aid, Geldof co-founded 8 Miles, the Africa-focused private equity firm that bought a majority stake in the Ugandan chicken farm.

Named after the shortest distance between Europe and Africa – at Gibraltar – the firm said it aimed “to deliver improved environmental, social and governance outcomes in the creation of market-leading African companies.”

On its website the for-profit firm says it aims to “contribute to the economic development of the countries in which the Fund invests.” It promotes investments in “companies to inspire Africa” and hopes to make substantial returns for investors, according to a confidential memorandum. It has signed the U.N.-supported Principles for Responsible Investment, which commit companies to respecting environmental, social and other corporate standards.

But in an annual financial report filed with U.K. regulatory authorities, the firm says its “principal objective” is “creating capital growth and realizing capital gains.” The fund raised about $150 million and by 2017 had invested nearly all of it in eight companies, according to an 8 Miles financial statement for that year filed in the United Kingdom.

8 Miles has taken stakes in an Ethiopian wine company, a Ugandan bank and an Egyptian manufacturer of resins for lacquer, varnishes and plastics. Among the investments in 2014 was $9 million in Biyinzika Poultry International Ltd., Uganda’s leading chick producer. The company’s name means “With God, all things are possible.”

Leaked Conyers Dill & Pearman records reveal that 8 Miles spent thousands of dollars on advice and services that might reduce taxes. Advisers repeatedly raised tax issues, including discussions on investment vehicles preferable for “tax reasons,” according to emails.

Under “taxation implications” in a business plan dated March 2013, Conyers employees wrote that the partnership “may require a tax residency certificate” to “benefit from the double tax agreement network.” Four of the seven African countries in which the fund’s companies operate had a tax treaty with Mauritius at the time of the fund’s investments.

The partnership eventually set up a Mauritius management company, Eight Africa Management (Mauritius) Ltd., which received a Global Business License and became eligible for Mauritius tax rates, according to the 8 Miles 2017 annual report.

Biyinzika Poultry International Ltd., Uganda’s leading chick producer.
Biyinzika Poultry International Ltd., Uganda’s leading chick producer. Image: Will Fitzgibbon / ICIJ

The 8 Miles spokesman told ICIJ that: “The companies we invest in, pay all taxes in their home jurisdiction in Africa”  and sale proceeds are paid back into Mauritius only after a company’s sale.

The fund declined to provide financial records from Mauritius that could detail management fees and other money flows.

8 Miles said tax treaties “are a matter between the governments who sign these agreements and we comply with such agreements but we do not make them.”

Ugandan tax officials say that corporate abuse of the treaty with Mauritius has been rampant. In December 2018, Uganda sent four officials to Mauritius to renegotiate the agreement. Mauritian officials resisted changes to the most troublesome elements of the treaty, one participant told ICIJ.

“It’s a very bad treaty,” a Ugandan tax official told ICIJ. “Lots of problems.”

Batting for tax avoidance

When 8 Miles wanted offshore advice, it turned to the Mauritius arm of Conyers Dill & Pearman.

Founded in Bermuda in 1928 by Reginald Conyers, a speaker of the island’s parliament and a first-class cricketer, the firm is widely credited with creating the world’s first-ever offshore company. The “exempted” Bermuda company (not subject to requirements imposed on local companies) benefited members of the American Noble family, heirs to the Lifesavers candy fortune.

In a history of Conyers published in 1998, one attorney is quoted as describing a typical client as someone “who would rather spend $10,000 on legal bills than pay $5,000 to Uncle Sam.”

Documents from Mauritius Leaks identify companies from United States, Europe and Asia, as well as homegrown African investors, among Conyers’ clients.

In a section marked “not for publication” in its 2017 submission to a law firm-ranking competition, Conyers listed eight confidential clients. One of the eight was the Industrial and Commercial Bank of China, which Conyers advised on a $3 billion loan to MTN Group, Africa’s largest mobile phone company. Conyers also said it guided the $65 billion merger of two gas and engineering companies. Accompanying this particular disclosure was this emphatic statement: “CONYERS’ INVOLVEMENT IN THIS MATTER IS HIGHLY CONFIDENTIAL (AS IS ANY MAURITIUS CONNECTION ETC).” The documents do not suggest these transactions involved tax avoidance.

In 2017, three Conyers directors, Sameer Tegally, Ashvan Luckraz and Sonia Xavier, bought Conyers’s Mauritius assets. They renamed the business-management operation Venture Corporate Services and the law practice Venture Law Ltd.

As part of the sale, a local accounting firm proposed three routes for the directors to avoid or reduce taxes paid on the sale in Mauritius, according to draft tax advice.

Tegally, Luckraz and Xavier did not respond to questions, including any tax advice they did or did not follow.

And where there are tax shelters, there are Big Four accounting firms. KPMG, PricewaterhouseCoopers, Deloitte and EY all have offices on Mauritius.

In 2015 KPMG advised Ubongo Group, Africa’s largest producer of educational children’s television programs, whose shows reach 11 million households in 31 countries. Eyeing an expansion, the Tanzania-based company predicted a 35-fold increase in revenue over six years, according to a financial model.

KPMG provided advice on the “economical means of Ubongo Mauritius extracting profits from Ubongo Tanzania,” according to a Ubongo planning document. One KPMG suggestion was that the Mauritius subsidiary lend money to the Tanzanian one, so that the money used to repay the loan would be taxed at 3% in Mauritius rather than 30% in Tanzania.

Ubongo told ICIJ that it took advice from KPMG about how to grow across Africa, but did not follow through with the plans or recommendations. “We canceled the investment round before receiving any funds, and instead re-registered as a non-profit organization to better align our funding and structure with our mission,” Ubongo told ICIJ.

KPMG did not comment on specifics, but said its “tax professionals act lawfully” and “with integrity.”

‘No nefarious agenda’

Mauritius’ tax benefits are popular with African elites as well as foreign ones.

Patrick Bitature owns telecommunications, energy, media and hotel companies across Uganda. One of Uganda’s richest men, who once sat on the boards of one-third of the companies on the Kampala Stock Exchange, Bitature has been close to Uganda’s authoritarian president, Yoweri Museveni, according to The Indian Ocean Newsletter, a respected news outlet.

He is also majority owner of Electro-Maxx, which runs Uganda’s largest thermal power plant, located in the eastern town of Tororo. It is the first African-owned and financed company to produce power on the continent.

In 2011, the investment company African Frontier Capital LLC proposed a $17.5 million investment in Electro-Maxx that passed through a newly incorporated Mauritius company named African Frontier I LLC, according to minutes of the African Frontier board. The proposal included a  $2.5 million personal loan to Bitature, the minutes say.

The company’s minutes, dated June 2011, also said it would apply for a tax residency certificate every year to “benefit” from the tax treaty between Uganda and Mauritius.

Robert Mwanyumba, a tax researcher focused on East Africa, said that if the company used the treaty with Mauritius, it would have been subject to its low corporate income tax rate instead of Uganda’s 30% rate.

Bitature confirmed the existence of a “bona fide” transaction and said the use of a tax treaty was a question for African Frontier, which did not provide a comment on the subject.

Responding to ICIJ media partner The Daily Monitor, Bitature said that Electro-Maxx sought external financing when it could not raise money for a new project. “The transaction was carried out within the provisions of the tax laws and fully accounted for in tax returns shared with” the Uganda Revenue Authority, he said.

“All taxes if any” were paid, Bitature said, adding “there was absolutely no nefarious agenda.”

African Frontier Capital, via the Mauritius company African Frontier I, ended its investment in Electro-Maxx in 2014. It told ICIJ that the investment was “a completely arms-length transaction” that fully complied with the laws of the countries involved.

Under pressure

In January, after years of complaints from its treaty partners and under pressure from international institutions, Mauritius overhauled the tax laws governing its offshore sector.

Gone is Global Business License 1, the form of shell company that poorer nations denounced as an exploitative tax-avoidance tool.

Mauritius now requires investors to have reasonable local staffing and to spend money on the island that reflects the activities of a real office – known as “enhanced substance” – to benefit from tax treaties or low tax rates. Shell companies are a thing of the past, Mauritius assures outsiders.

They can say they’re doing it by the book, but the book is full of technical tricks, and Mauritius has some very skilled technicians. – Sol Picciotto

Bemoaning the new rules, one member of Parliament blamed the Panama Papers and Paradise Papers investigations by ICIJ, among other exposés, for soiling the offshore industry’s reputation. “Under pressure from the OECD and the European Union, who have at heart only their interest to further tax their citizens and corporations, Mauritius, once again, has kowtowed,” lawmaker Mohammad Reza Cassam Uteem said.

Corporations, fund managers and tax advisers warned the changes would make Mauritius less attractive for investment.

Others, however, suggest that its reforms may be little more than box-checking designed to keep the country off international blacklists. Mauritius, they say, has already found ways to continue providing tax-avoidance opportunities.

The island reluctantly agreed, for example, to a rule that allows a Mauritius treaty partner to deny tax-treaty benefits to a multinational corporation that opens in Mauritius with the “principal purpose” of exploiting those benefits. Experts say that poorer countries will rarely be able to make use of that provision: Denying treaty benefits to a corporation will require technical, financial and political resources that a developing country may not have.

Sol Picciotto, emeritus professor at Lancaster University law school in England, said of Mauritius: “They play the game so as not to be denounced as uncooperative, but they can maneuver within the grey areas of the rules. They can say they’re doing it by the book, but the book is full of technical tricks, and Mauritius has some very skilled technicians.”

This year, Setsoto Ranthocha, the Lesotho tax official, negotiated with Mauritius to fix a treaty that he says has cost his country dearly. “They are tough negotiators,” Ranthocha said of his Mauritius counterparts. “They know what they are doing.”

Meanwhile, Mauritius is pursuing new treaties with 16 African states, bidding to bring its coverage to nearly 60% of the continent.

Contributors: Dean Starkman, Richard H.P. Sia, Fergus Shiel, Tom Stites, Joe Hillhouse, Delphine Reuter, Antonio Cucho, Emilia Diaz-Struck, Amy Wilson-Chapman, Gerard Ryle, Hamish Boland-Rudder, Miguel Fiandor Gutiérrez, Karrie Kehoe, Shinovene Immanuel, Lazarus Amukeshe, Ritu Sarin, Simon Mkina, Frederic Musisi, Tabu Butagira, Axcel Chenney, Jeremy Merrill and John Keefe.

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