Ireland Surpasses Mauritius in Preferred FPI Destinations

As of June 30, 2024, Ireland has overtaken Mauritius to secure the fourth spot among preferred destinations for Foreign Portfolio Investors (FPIs) routing funds into India. Ireland boasts assets under custody (AUC) totaling Rs 4.41 trillion, slightly edging out Mauritius which recorded Rs 4.39 trillion. The shift highlights Ireland’s appeal, with a 26% increase in AUC in the first half of the year compared to Mauritius’ 11% uptick.

Regulatory Challenges and Shifting Preferences

Legal experts and custodians attribute Mauritius’ decline to prolonged approval processes for new funds, delaying fund registrations. Heightened scrutiny on Mauritius-based funds investing in India has also contributed to these delays, prompting FPIs to explore alternatives. European jurisdictions like Luxembourg, Ireland, and France offer attractive tax treaty benefits, such as zero tax on cash equities for funds based in Ireland or Luxembourg.

Impact of Tax Treaty Amendments

In March, Mauritius and India amended their Double Taxation Avoidance Agreement (DTAA), aligning with OECD’s base erosion and profit shifting (BEPS) framework. However, industry concerns and pushback have delayed the treaty’s final approval, pending decisions expected after Mauritius’ upcoming general elections in November. Uncertainty persists among funds regarding eligibility for grandfathering benefits under the amended treaty, influencing investment decisions moving forward.