Blue Bank Co Ltd is incorporated and managed in Malaysia. It wishes to make loans to persons
Question:
Blue Bank Co Ltd is incorporated and managed in Malaysia. It wishes to make loans to persons in Mauritius. Blue Bank Co Ltd sets up a representative office in Mauritius. It rents office space and sends four of its employees to work there. Blue Bank Co Ltd also hires two local clerical staff. The employees collect information on privatization and economic developments in Mauritius. Any potential clients who enquire at the representative office about getting loans from Blue Bank Co Ltd are referred to head office which processes all loan applications, including documentation. In the course of making decisions about loan applications, head office often asks the representative office to make various enquiries and provide information about potential borrowers.
Required: Does Blue Bank Co Ltd have a permanent establishment in Mauritius? If so, what profits are taxable there?