The DBA provides for reduced rates of withholding tax, as follows: Naomi Fowler ■ India and renegotiation of its double taxation agreement with Mauritius: an update There is no withholding tax when the royalty is paid by a company from the foreign income of the Mauritian company. Reduced withholding tax rates apply only if the recipient of the income is the beneficial owner of the income. The Supreme Court of Kenya annulled in March 2019 a double taxation agreement (DBA) between Kenya and Mauritius. Here you will find an article from EY Tax Insights with more details on the invalidation of the DBA. Japan (whose share tripled, from 3% in 2017 to 9% in 2018) and Great Britain (whose share quadrupled, from 1% to 4%), are other jurisconsults, who have also risen sharply in India. .