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Tax Mind - January 2026

J. Kalachand: retroactivity, penalties and the rule of law – where could it go next?

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For every action, there is an equal and opposite reaction. Newton’s third law was very clear on this but one can wonder – does time have an impact on that?

Now, surprising as it may be, this article is not about physics, but about the limits of retroactivity in tax law, examined through the case of J. Kalachand & Co. Ltd v Director-General, Mauritius Revenue Authority (“Kalachand”).

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Anthony Leung Shing, ACA, CTA

Anthony Leung Shing, ACA, CTA

EMA Deputy Regional Senior Partner, Country Senior Partner, PwC Mauritius

Tel: +230 404 5071

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Dheerend Puholoo, ACCA

Dheerend Puholoo, ACCA

Tax Leader, PwC Mauritius

Tel: +230 404 5079

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