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Mauritius is a treaty-based jurisdiction and it holds treaties with numerous countries. Our experts are well-versed in the interpretation of Double Tax Treaties and will advise you on the application of treaties and the most “tax efficient” way to use them.

Tax Residency is central to the interpretation and application of DTAs. For a global business vehicle to be “resident” in Mauritius it must be centrally managed and controlled from Mauritius. The following conditions must be met to ensure effective control and management in Mauritius.

1. The vehicle shall at all times have at least two directors resident in Mauritius. The resident directors shall be of appropriate caliber who can exercise independence of mind and judgement.
2. All meetings of the Board of Directors shall be held, chaired and minuted in Mauritius.
3. The company shall at all times keep all its accounting records at its registered office in Mauritius.
4. It shall at all times maintain its principal bank account in Mauritius.

Tax Residence Certificates (TRC’s) are issued by the Mauritius Revenue Authority and are renewable annually.

A GBC 1 is liable to corporate tax at 15% but may claim a foreign tax credit in respect of the actual foreign tax suffered or 80% presumed foreign tax credit, whichever is higher. As such, a GBC1 is subject to a maximum effective tax rate of 3%.

A GBC 2 is exempt from tax in Mauritius but it cannot benefit from the DTAs since it does not have tax residency in Mauritius.

Trusts are subject to local taxation only if they elect to be “resident” in Mauritius. In such cases the Trust will be taxable on its chargeable income at a rate of 15% p.a. Being liable to tax in Mauritius, a resident trust can benefit from the Mauritius tax treaty network. Non-resident beneficiaries of a resident or non-resident trust are tax exempt on the distributions received from the trust.

Companies are required to submit their annual tax returns within 6 months from the end of the month in which their accounting year ends. Moreover, all companies deriving gross income and exempt income exceeding MUR 10 million (approx. USD 320,000) have the legal obligation to file their annual tax returns and effect their tax payments electronically.

Advance Payment System (APS)
Under the Advance Payment System (APS) companies are required to submit APS statements and pay tax on a quarterly basis.