Africa and the Indian Ocean rim
Mauritius has spent three decades building itself into a conduit for investment into Africa — through double-taxation treaties, investment promotion and protection agreements, a common-law-and-civil-law hybrid legal system that international counsel can read, and a fund administration industry. The proposition is not tax arbitrage; jurisdictions that compete on rate alone are replaceable. The proposition is legal certainty applied to transactions whose underlying assets sit in markets where certainty is harder to obtain.