Should our India investment be routed through Mauritius, Singapore, or UAE?

Mauritius and Singapore were the default choice for decades because their treaties exempted capital gains from Indian tax. That changed with protocol amendments effective for shares acquired after 1 April 2017 (Mauritius) and 2017 more broadly (Singapore) — new investments through either jurisdiction are now taxed in India on capital gains like any other route.

The India-UAE DTAA currently treats capital gains as taxable only in the UAE, with no Indian withholding on exit. On dividends, UAE applies a flat 10% withholding, while Mauritius can offer a reduced 5% rate above a shareholding threshold — so Mauritius can still edge ahead if dividend flow matters more than capital gains to your specific plan.

Whichever jurisdiction is chosen, genuine local operating substance is required to withstand India's GAAR and the treaty's Principal Purpose Test — a shell entity in any of these jurisdictions carries the same risk.