Mauritius Tax Regime

Mauritius combines a low, flat corporate income tax of 15% with an extensive treaty network and a well-established international financial centre regime. Resident companies are taxed on worldwide income with credit relief for foreign tax; a partial-exemption system shelters 80% of certain foreign-source income streams, giving a maximum effective rate of 3% on qualifying flows. Capital gains are outside the tax net, there is no withholding on dividends paid by resident companies, and there is no inheritance or net wealth tax. The system has evolved rapidly in recent years: substance requirements now underpin the Global Business Licence (GBL) regime, a Qualified Domestic Minimum Top-up Tax (QDMTT) applies to large multinational groups from the year of assessment commencing 1 July 2025, and a series of levies — Corporate Social Responsibility, Corporate Climate Responsibility and a temporary Fair Share Contribution — sit on top of the headline rate for larger domestic businesses.

1.1 Sources

Primary legislation includes the Income Tax Act 1995, the Value Added Tax Act 1998, the Mauritius Revenue Authority Act 2004, the Financial Services Act 2007 (governing Global Business and Authorised Companies) and annual Finance Acts, together with regulations and rulings issued by the Mauritius Revenue Authority (MRA).

1.2 Recent developments

The QDMTT took effect for years of assessment commencing 1 July 2025, applying the 15% global minimum to Mauritius members of multinational groups with consolidated revenue of EUR 750 million or more; returns and payment are due within 15 months of the fiscal year-end, with a designated-filer notification due within six months. A temporary Fair Share Contribution applies from 1 July 2025 to 30 June 2028: 5% of chargeable income for corporates taxed at the standard 15% rate (2% for those taxed at 3%) where chargeable income and supplies exceed MUR 24 million, with GBL companies and tax-holiday beneficiaries excluded. The Corporate Climate Responsibility (CCR) Levy of 2% of chargeable income applies from the year of assessment commencing 1 July 2024 to companies with turnover above MUR 50 million. From the year of assessment commencing 1 July 2026, an Alternative Minimum Tax of 10% of adjusted book profit applies to companies in the hotel, insurance, financial intermediation, real estate and telecommunications sectors, and at least 50% of CSR funds set up on or after 1 January 2026 must be remitted to the MRA.

Headline statutory corporate income tax rate for a resident company. Where sub-national (state, provincial, cantonal or municipal) corporate taxes apply, the combined rate reported by the OECD is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

Top marginal statutory personal income tax rate on employment income for a resident individual. Where sub-national (state, provincial, cantonal or municipal) income taxes are a standard part of the system, the combined top rate is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

2.1 Rates and residence

Companies resident in Mauritius are taxed on worldwide net income at a flat rate of 15%. A company is resident if it is incorporated in Mauritius or has its central management and control there; an entity holding an Authorised Company authorisation — incorporated in Mauritius but managed and controlled abroad — is treated as non-resident and taxed only on Mauritius-source income, filing a return within six months of its year-end. Companies engaged in the export of goods are taxed at 3% on chargeable income attributable to exports under a prescribed formula, and Freeport operators and private Freeport developers engaged in manufacturing pay 3% on local-market sales subject to substance conditions. Banks are taxed at 5% on the first MUR 1.5 billion of chargeable income and 15% on the remainder, plus a special levy of 5.5% of leviable income.

On top of the headline rate, larger companies bear the CSR contribution (2% of prior-year chargeable income, with at least 75% — 50% for funds set up from 2026 — remitted to the MRA), the 2% CCR Levy where turnover exceeds MUR 50 million, and, between July 2025 and June 2028, the Fair Share Contribution described in section 1.2. For banks, aggregate income tax, levies and contributions are capped at 35% of chargeable income from domestic operations. Local governments levy no income taxes.

2.2 Dividends and the partial exemption

Dividends paid by Mauritius-resident companies are exempt in the hands of resident and non-resident shareholders alike, and no dividend withholding applies. In place of a classical participation exemption, all companies — including GBL companies — qualify for an 80% exemption on specified foreign-source income: foreign dividends not deducted in the source country, interest income, income from ship and aircraft leasing, leasing and provision of international fibre capacity, peer-to-peer lending interest, reinsurance and reinsurance brokering, and aircraft sale, financing, asset management and related advisory income. The exemption is conditional on prescribed substance in Mauritius, and no foreign tax credit may be claimed on income sheltered by the 80% exemption; taxpayers may instead elect to be taxed in full with credit for underlying and withholding foreign tax. Interest earned by collective investment schemes and closed-end funds enjoys a 95% exemption. Capital gains, including gains on the disposal of shares, are not taxed.

2.3 Income determination and deductions

Taxable income is based on accounting profit adjusted under the Income Tax Act. Expenditure is deductible where exclusively incurred in the production of gross income; non-deductible items include capital expenditure, provisions of a capital nature, income tax itself and expenditure attributable to exempt income. Tax depreciation takes the form of annual allowances at prescribed rates (for example on industrial premises, plant and machinery, and computer equipment), with accelerated and 100% first-year allowances for specified green and productivity-enhancing assets. Because capital gains are outside the tax base, losses of a capital nature are equally non-deductible, and expenditure must be apportioned between exempt and taxable streams under the partial-exemption rules.

2.4 Interest limitation

Mauritius has not enacted an EBITDA-based interest-limitation rule of the ATAD type, and there is no formal thin-capitalisation ratio. Interest deductibility instead rests on general principles: the borrowing must be incurred exclusively in the production of gross income, interest attributable to exempt income (including income within the 80% partial exemption) is proportionately non-deductible, and related-party interest must satisfy the arm's-length requirement of the Income Tax Act. The MRA scrutinises back-to-back and shareholder financing in the global business sector on these grounds.

2.5 Losses

Trading losses may be carried forward for five income years; the portion of a loss attributable to annual allowances on capital expenditure may be carried forward without time limit. There is no carryback. Carried-forward losses lapse where there is a change of more than 50% in shareholding, unless the change is exempted (for example on succession within manufacturing companies or where conditions for safeguarding employment are met). Losses of the 3%-taxed export segment and the 15% segment are ring-fenced through the apportionment formula.

2.6 Group taxation

There is no fiscal consolidation or group-relief regime: each Mauritius company is assessed on a stand-alone basis, and losses cannot be surrendered between group members. Group structuring therefore relies on the dividend exemption, the absence of capital gains tax on intra-group disposals and, where relevant, exemptions from land transfer duties for qualifying intra-group real-estate transfers. Country-by-country reporting obligations apply to Mauritius-headquartered groups and constituent entities of foreign groups meeting the EUR 750 million consolidated-revenue threshold.

2.7 Controlled foreign companies

CFC rules apply since 1 January 2019. Where a Mauritius resident company (alone or with associated enterprises) holds more than 50% of a foreign company that pays less than half the Mauritius tax it would have paid at home, non-distributed income arising from non-genuine arrangements put in place essentially to obtain a tax benefit may be attributed to the Mauritius parent, based on the significant-people functions performed in Mauritius. Exclusions apply where accounting profits or the non-trading income of the CFC are de minimis or the CFC's profits reflect real economic activity.

2.8 Transfer pricing

Mauritius has no comprehensive transfer-pricing code, but the Income Tax Act requires transactions between related parties to be at arm's length, and the MRA applies this provision — informed by international practice — to cross-border financing, services and licensing arrangements. There is no statutory master-file/local-file documentation requirement, though taxpayers are expected to be able to substantiate pricing on enquiry; CbCR regulations implement the EUR 750 million reporting standard. Advance rulings from the MRA are available and are commonly used to obtain certainty on cross-border arrangements.

2.9 Incentives

The incentive architecture is broad: tax holidays of five to ten years apply to a long list of licensed activities, including asset and fund managers meeting employment conditions, family offices, innovation-driven companies deriving income from intellectual property developed in Mauritius (eight years), and operators in emerging sectors. The 80% partial exemption and the 3% export regime function as permanent rate reducers. An investment tax credit is available for manufacturing investment in plant and machinery, and double deductions apply to specified R&D and market-development expenditure. Freeport operators enjoy the 3% regime for manufacturing sales locally and duty-free operations for re-exports. Tax-holiday income is excluded from the Fair Share Contribution.

2.10 Pillar Two

Mauritius has implemented the global minimum tax through a QDMTT only, effective for years of assessment commencing on or after 1 July 2025; it has not enacted an income inclusion rule or undertaxed profits rule. Every Mauritius member of an in-scope group (consolidated revenue of EUR 750 million or more in at least two of the last four fiscal years) pays QDMTT where the combined effective rate of the group's Mauritius members is below 15%. The QDMTT return and payment are due within 15 months of the fiscal year-end, and each resident constituent entity must notify the MRA of the designated resident filer within six months of the year-end. Investment funds, pension funds and real-estate investment vehicles, among others, are excluded. Groups relying on the 80% exemption, tax holidays or the 3% regimes should model their Mauritius effective rate carefully, as the QDMTT can claw the benefit back to 15%.

2.11 Branch income and reorganisations

A branch of a foreign company carrying on business or having a place of business in Mauritius is taxed at the same 15% rate on Mauritius-source profits (and on foreign profits only if remitted to or derived through Mauritius operations); there is no branch profits or remittance tax. Because there is no capital gains tax, most share-for-share exchanges, amalgamations under the Companies Act and intra-group transfers can be executed without income-tax cost, although land transfer tax and registration duty must be managed on transactions involving Mauritius immovable property. Migration of companies into and out of Mauritius is possible by continuation under the Companies Act, with no exit tax on unrealised gains.

3.1 Residence and rates

Individuals are resident if domiciled in Mauritius (unless their permanent place of abode is abroad), present for 183 days or more in an income year, or present for an aggregate of 270 days over the current and two preceding income years. Residents are taxed on Mauritius-source income and on foreign income remitted to Mauritius; non-residents are taxed on Mauritius-source income only. Since 1 July 2023 individual income is taxed under a progressive schedule running from 0% on the first band of annual net income through intermediate rates of 2%, 4%, 6%, 8%, 10%, 12%, 14%, 16% and 18%, to a top rate of 20% on the highest band; the former solidarity levy on high earners has been abolished. The income year runs from 1 July to 30 June, and reliefs are delivered through income-exemption thresholds and deductions for dependants, medical insurance and specified savings.

3.2 Investment income, gains and property

Dividends from Mauritius-resident companies are exempt; foreign dividends and foreign interest are taxable on remittance for residents, with credit for foreign tax. Local bank interest earned by individuals is broadly exempt, while other interest is taxable at the progressive rates. There is no capital gains tax, so gains on shares, securities and other investments are outside the net; frequent dealing in property or securities can, however, be characterised as a taxable trade. Rental income is taxable with deductions for interest and expenses. There is no net wealth tax and no estate duty or inheritance tax; transfers of immovable property attract land transfer tax at 5% payable by the seller and registration duty at 5% payable by the buyer.

3.3 Social contributions and payroll

The Contribution Sociale Généralisée (CSG) replaced the former pension contribution system: employees contribute 1.5% of remuneration up to MUR 50,000 per month and 3% above it, with employers contributing 3% and 6% respectively; participation by the self-employed is at prescribed flat amounts. Employers also contribute 2.5% to the National Savings Fund (employee 1%) and a 1.5% training levy under the HRDC scheme. Employers operate PAYE withholding on emoluments monthly, remit by the end of the following month (electronically), and file annual returns of emoluments; a portable retirement gratuity fund regime covers end-of-service gratuities for private-sector workers.

3.4 Inbound individuals

Mauritius actively courts inbound talent and investors: occupation permits for professionals, investors and self-employed persons double as residence permits, and a premium visa allows remote workers to reside in Mauritius with foreign income taxed only on remittance, with money spent in Mauritius through foreign cards not treated as remitted. Expatriates working for global business companies and asset managers may access specific exemptions, and returning members of the Mauritian diaspora enjoy a ten-year exemption on foreign income under the diaspora scheme. There is no exit tax on individuals ceasing residence. Non-citizens acquiring residential property under sanctioned schemes (IRS/RES/PDS and smart cities) obtain residence rights above prescribed investment thresholds.

There is no withholding tax on dividends paid by resident companies. Interest paid by any person (other than banks and certain deposit-taking institutions paying individuals) to non-residents attracts 15% withholding, subject to exemptions — notably interest paid by GBL companies out of foreign-source income and interest on qualifying bonds and sukuks. Royalties paid to non-residents bear 15% withholding (10% for residents), again with an exemption where paid by a GBL company out of foreign-source income to a non-resident. A domestic withholding system (TDS) also applies at modest rates to rent, contractor payments and specified professional fees paid to residents. The treaty network of some 46 in-force conventions — with particular depth in Africa and Asia — commonly reduces interest and royalty withholding to between 0% and 10%, and Mauritius has ratified the multilateral instrument, so principal-purpose-test screening applies to treaty claims. Relief at source is available on certification of residence; substance in Mauritius is essential for treaty access given source-country scrutiny of conduit arrangements.

Because dividends leave Mauritius free of withholding and capital gains are untaxed, the practical withholding analysis usually concentrates on inbound flows: source-country withholding on dividends, interest and royalties received by Mauritius holding and financing companies, and the interaction of treaty relief with the 80% partial exemption (which forfeits the foreign tax credit). Outbound structures should confirm that payments fall within the GBL foreign-source exemptions before assuming zero withholding.

5.1 General anti-avoidance and substance

The Income Tax Act contains a general anti-avoidance rule empowering the Director-General to counteract transactions whose sole or dominant purpose is the obtaining of a tax benefit, alongside specific arm's-length and expenditure-apportionment provisions. Substance requirements are central to the regime: GBL companies must be managed and controlled from Mauritius (resident directors, principal bank account, accounting records and statutory financial statements in Mauritius, board meetings with local direction) and must satisfy core-income-generating-activity tests — adequate local expenditure and employment — to access the 80% partial exemption and treaty benefits. The Financial Services Commission and the MRA police these conditions, and failure jeopardises both the licence and the tax outcome.

5.2 Treaty abuse, exchange of information and reporting

Mauritius has ratified the BEPS multilateral instrument, importing the principal-purpose test into most of its treaties, and participates in the Inclusive Framework. It exchanges information under the OECD common reporting standard (CRS) and FATCA, implements country-by-country reporting with exchange, and maintains a register of beneficial ownership. Having exited the FATF grey list and the EU list of high-risk countries in 2021-22 after a substantial AML/CFT overhaul, Mauritius now emphasises its compliance credentials; economic-substance-style scrutiny is applied at licensing and renewal. CFC attribution (section 2.7) and the QDMTT complete the anti-base-erosion architecture; there are no hybrid-mismatch or exit-tax rules of the ATAD type.

6.1 VAT

VAT applies at a standard rate of 15% on taxable supplies of goods and services in Mauritius and on imports. Registration is compulsory where annual turnover of taxable supplies exceeds MUR 3 million (reduced from MUR 6 million with effect from 1 October 2025 under the Finance Act 2025), and for specified professions regardless of turnover; voluntary registration is available. Exports of goods and services are zero-rated, as are basic foodstuffs and certain utilities; exempt supplies include financial services, education, health and residential property rental. Returns are filed monthly where turnover exceeds MUR 10 million and quarterly otherwise, with payment by the end of the following month (electronic filers benefit from extended dates). Input VAT is creditable against output VAT, with repayment available for zero-rated suppliers and capital-goods claims; a reverse charge applies to imported services used to make exempt supplies and to digital and electronic services supplied from abroad.

6.2 Transaction, property and other taxes

Land transfer tax of 5% is payable by the transferor and registration duty of 5% by the transferee on transfers of immovable property (with exemptions for first-time buyers within thresholds and various scheme reliefs); leases and certain documents attract registration duties at fixed or ad valorem rates. Excise duties apply to alcohol, tobacco, petroleum products, sugar-sweetened beverages and motor vehicles, alongside customs duties on a narrow band of imports. Sector levies include the special levy on banks (5.5%), the gambling levy, passenger and tourism fees, and an environment protection fee in the hotel sector. There is no capital gains tax, no net wealth tax, no inheritance or gift tax and no municipal income taxation; municipal rates apply to properties within urban areas.

7.1 Filing, assessment and audit

The fiscal year runs from 1 July to 30 June, but a company files by reference to its own accounting year-end: the annual return and self-assessed tax are due within six months of the end of the month in which the accounting period ends, filed electronically with the MRA. Companies with turnover above MUR 10 million operate the Advance Payment System (APS), filing quarterly statements and paying tax in instalments based on the preceding year's results or current-quarter income, with the balance due with the annual return; CSR (75%, or the applicable share) and, where relevant, AMT instalments ride on the APS cycle. Employers file monthly PAYE and contribution returns. The MRA conducts risk-based desk and field audits and may raise assessments generally within three years of the year of assessment, extended in cases of fraud or non-submission.

7.2 Rulings, objections and appeals

Taxpayers may seek binding advance rulings from the MRA on the application of the Income Tax Act to specific transactions, and private rulings are published in anonymised form. A taxpayer disputing an assessment must object within 28 days (with payment of a prescribed portion of the tax in certain cases); unresolved objections proceed to the independent Assessment Review Committee, then on points of law to the Supreme Court and ultimately the Judicial Committee of the Privy Council. Penalties apply for late filing, late payment and underestimation under APS, with interest at prescribed rates; the MRA operates periodic voluntary disclosure and arrears settlement schemes with penalty remission. Mutual agreement procedures are available under the treaty network.

Authorised Companies file within six months of year-end even though treated as non-resident. Underestimation of APS instalments beyond tolerance attracts penalties, so groups typically true-up in the final quarter; QDMTT data collection should begin well before the 15-month deadline given the group-level computations required.

9.1 Entity choice

The domestic company under the Companies Act 2001 is the standard operating vehicle. Internationally oriented investors choose between the GBL company — resident, treaty-entitled, taxed at 15% with access to the 80% partial exemption, and subject to FSC licensing and substance conditions — and the Authorised Company, which is non-resident for tax, outside the treaty network, and suited to pure offshore trading or holding without Mauritius-taxed income. Protected cell companies serve funds and insurance; limited partnerships, trusts and foundations (both now taxed as resident unless non-resident conditions are met) support fund and private-wealth structuring. Branches of foreign companies are taxed at 15% on Mauritius-source profits with no remittance tax.

9.2 Structuring and incentives

Mauritius remains a leading platform for investment into Africa and Asia: the combination of the 15% rate, the 80% exemption on foreign dividends and interest, no capital gains tax, no dividend withholding and 46 treaties can produce very low effective rates on holding and financing income — provided substance requirements are genuinely met and principal-purpose-test risk in source countries is managed. Fund managers should weigh the tax-holiday regimes and the CIS 95% interest exemption; manufacturers and exporters can pair the 3% export rate with Freeport logistics. Large groups must overlay the QDMTT: where the Mauritius effective rate is pulled below 15% by exemptions or holidays, top-up tax will restore it, so incentive value for in-scope groups is now largely confined to timing and below-threshold entities. The temporary Fair Share Contribution and CCR Levy should be built into domestic-business models through 2028.

9.3 Worked effective-rate illustration

A domestic trading company (turnover MUR 80 million, so the CCR Levy applies; chargeable income below the MUR 24 million Fair Share threshold) earns chargeable income of MUR 20,000,000. Income tax at 15% is MUR 3,000,000. The CSR contribution at 2% adds MUR 400,000 and the CCR Levy at 2% a further MUR 400,000. The total burden is 3,000,000 + 400,000 + 400,000 = MUR 3,800,000, an effective rate of 3,800,000 / 20,000,000 = 19.0%. By contrast, a GBL financing company earning MUR 20,000,000 of qualifying foreign interest applies the 80% exemption: taxable income is 20% × 20,000,000 = MUR 4,000,000, tax at 15% is MUR 600,000, and the effective rate is 600,000 / 20,000,000 = 3.0%; no CSR or Fair Share Contribution applies, but no foreign tax credit may be claimed on the exempt portion, and an in-scope multinational group would face QDMTT topping the Mauritius effective rate back up to 15%.

9.4 Compliance

Expect electronic filing throughout: annual corporate returns, APS statements, monthly PAYE, CSG and TDS remittances, and VAT returns, all through the MRA's platforms. GBL companies must additionally maintain FSC licensing compliance — resident directors, audited financial statements filed with the FSC, and evidence of core income-generating activities and local expenditure. Beneficial-ownership information must be kept current with the Registrar of Companies. In-scope multinational groups should budget for QDMTT registration, GloBE-quality data collection and the 15-month return cycle, and sector companies (hotels, insurance, financial intermediation, real estate, telecoms) should model the 10% book-profit AMT from July 2026.