The NatWest ruling suggested that the Mauritius-India treaty could no longer be used. But the AIG ruling showed that a bona fide use of Mauritius as an investment base was consistent with use of the treaty. The DLT ruling was to similar effect. Power projects and infrastructure, offshore debt funds and investment in real estate are the principal investments in India made out of Mauritius. Outbound investment from India is being liberalised and will offer new opportunities for the use of Mauritius - notably for investment in European countries.
Investment flowing into China is huge.
There is also an Investment Protection and Promotion Agreement. This is most helpful to investors, but a good deal of knowledge, skill and experience is needed to make effective direct investment in China and to take advantage of the various tax incentives available. Portfolio investment, on the other hand, may find a good base in Mauritius. It may also find a base in Luxembourg - the treaty with China not excluding the 1929 holding company. Nor is there any UK tax charge when the UK company itself declares dividends to its shareholders out of its American income - and those shareholders do not have to be in a treaty country or a country in the European Union.