This study adduces evidence that demonstrates that the Kenya/Mauritius DTA will significantly affect Kenya’s revenue base. The study notes that the Kenya/Mauritius DTA has included a number of clauses on permanent establishments, business profits, dividends, interest and capital gains tax that may negate the country’s ability to collect taxes as these clauses have qualifying measures that are inconsistent with the UN Model Convention which is a benchmark for DTA negotiations conducted by developing countries.
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