Mauritius Challenging Transfer Pricing of Back-to-Back Management Fees and Loans

According to recent reports, the Mauritius Revenue Authority (MRA) has begun challenging the transfer pricing of payments for back-to-back management fees and loans with greater frequency. The challenges involve claims by the MRA for higher transfer pricing mark-ups, including with respect to management fees and loans going back several years. Note that Mauritius has no developed transfer pricing framework, but the MRA is empowered to make adjustments if transactions are deemed non-compliant …