International Tax Planning, Beneficial Ownership and Treaty Risk – A Practical Guide for Mauritius-Based Professionals

Speaker

Angelo Chirulli
About The Speaker

Mr Angelo Chirulli is a senior UK and international tax adviser, Tax Partner and CEO of Vectigalis AC Tax Limited. He is an ICAEW Chartered Accountant (FCA/BFP), ADIT-qualified international tax specialist, Trust and Estate Practitioner (TEP), member of the International Fiscal Association and Italian Dottore Commercialista / CPA. He has more than 26 years of experience across international tax, corporate tax, personal tax, restructuring tax, transfer pricing, treaty analysis, private client and cross-border structuring.

Angelo lectures and presents for professional audiences, including MBL Seminars, Redcliffe Training and ADIT / CIOT-related international tax education. His recent and forthcoming training topics include double tax treaties, the Multilateral Instrument, beneficial ownership transparency, CFCs, corporate residence, cross-border corporate structuring, offshore governance, Pillar Two, transfer pricing and cross-border M&A.

Upcoming Event

International Tax Planning, Beneficial Ownership and Treaty Risk - A Practical Guide for Mauritius-Based Professionals

  • August 4th, 2026
  • Online
  • 1 pm to 4 pm
  • Rs 18,000 (MQA Approved & HRDC Refundable up to 75%)
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Course Details
Course overview

International tax planning has changed materially in the post-BEPS environment. Structures that may once have been assessed mainly by reference to legal form and treaty wording are now tested through commercial rationale, beneficial ownership, substance, governance, transfer pricing, exchange of information, anti-abuse rules and documentaryevidence.

For Mauritius-based professionals, the practical question is not merely whether a structure produces a tax result, but whether the structure can be explained, supported and defended before banks, regulators, tax authorities, counterparties and clients. This course addresses the issues that typically arise when Mauritius companies, funds, holding platforms, treasury entities or service arrangements are used in wider cross-border structures.

Course Objectives
  • Explain the modern international tax planning environment and why BEPS, transparency and treaty anti-abuse rules have changed adviser risk.
  • Identify the main technical components of a defensible cross-border structure: residence, source, treaty entitlement, beneficial ownership, substance, transfer pricing and governance.
  • Analyse beneficial ownership and treaty risk in relation to dividends, interest, royalties, management fees and other cross-border payments.
  • Understand how the Multilateral Instrument and the Principal Purpose Test can affect treaty access and tax authority challenges.
  • Apply a practical Mauritius-focused risk review to holding, financing, IP, service and investment platform structures.
  • Prepare a documentary evidence file that supports commercial purpose, decision-making, control, substance and treaty entitlement.
  • Recognise when legacy structures require remediation, restructuring or enhanced governance documentation.
Learning outcomes

By the end of the course, participants should be able to:

  • Map a cross-border structure and identify the relevant tax flows, jurisdictions, parties, functions and risk points.
  • Distinguish between legal ownership, beneficial ownership, economic entitlement and effective control.
  • Assess high-level treaty access and treaty anti-abuse concerns in a Mauritius-related structure.
  • Apply practical PPT questions to common holding, financing and service company scenarios.
  • Identify beneficial ownership red flags, including back-to-back payments, limited discretion, circular cash flows, weak governance and insufficient substance.
  • Understand how board minutes, decision logs, contracts, intercompany agreements, service provider records and bank documents support the tax position.
  • Explain complex treaty and beneficial ownership issues to clients and internal stakeholders in a commercially useful way.
  • Use a structured adviser checklist to decide whether a tax position is robust, requires further evidence or needs remediation.
Course details

1. International tax planning in the post-BEPS environment

  • How international tax planning has moved from form-based structuring to substance, transparency and defendable implementation.
  • The role of OECD BEPS actions, exchange of information, economic substance and tax authority cooperation.
  • Practical distinction between commercial structuring, tax optimisation and unacceptable treaty-driven arrangements.
  • Why advisers must test structures across tax, legal, governance, accounting, regulatory and banking requirements.

2. Core building blocks of a cross-border tax structure

  • Residence, source and characterisation of income.
  • Corporate tax residence, central management and control and place of effective management.
  • Permanent establishment and dependent agent risk.
  • Withholding tax and treaty relief mechanics.
  • Transfer pricing and intercompany agreements.
  • CFC, anti-hybrid, GAAR/TAAR and Pillar Two awareness in investor jurisdictions.

3. Beneficial ownership and economic substance

  • Beneficial ownership of dividends, interest, royalties and service income.
  • Back-to-back arrangements, conduit company concerns and insufficient control over income.
  • Substance indicators: people, premises, decision-making, capability, risk assumption and contemporaneous evidence.
  • Board governance, minutes, authority matrices, service provider roles and real control.

4. Treaty anti-abuse and the MLI

  • MLI architecture and covered tax agreements.
  • Principal Purpose Test analysis and practical evidence.
  • PPT versus domestic anti-avoidance and beneficial ownership challenges.
  • Case patterns involving holding, financing, IP and regional service structures.

5. Practical adviser toolkit

  • A step-by-step treaty risk review process.
  • Questions to ask before claiming treaty relief.
  • Minimum evidence pack for Mauritius-based structures.
  • Red flags, remediation options and when to escalate for specialist advice.

Teaching methodology

  •  Illustrative Mauritius-focused and cross-border case studies designed to reflect real adviser, financial sector and corporate governance issues.
  • Interactive Q&A and issue-spotting questions during the session, with a dedicated final Q&A segment.
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