What annual local-substance spend do Mauritius and Singapore holding companies need to keep treaty benefits?

Both the India-Mauritius and India-Singapore treaties include a Limitation of Benefits (LoB) clause requiring a minimum level of annual local expenditure for an entity to access reduced treaty rates — this is meant to filter out shell companies that exist only on paper.

For Mauritius, the threshold is approximately ₹27 lakh (roughly USD 45,000) per year in local operating expenses. For Singapore, it's SGD 200,000 per year. These are recurring costs that need to be budgeted as an ongoing part of the structure, not a one-time incorporation expense — a holding company that can't sustain this spend won't reliably access the treaty benefit it was set up for.