MAURITIUS Law and Practice Contributed by: Fayaz Hajee Abdoula, Yashna Munbauhal and Yojna Beesoon, BLC Robert & Associates
tation (and application) of double taxation avoidance agreements modified by the Multilateral Convention. 9.2 Government Policy and Objectives Approach Mauritius has long demonstrated its commitment to OECD standards, having joined the Inclusive Frame - work in November 2017 to work alongside the OECD on implementing the BEPS minimum standards. Building on this commitment, Mauritius has aligned itself with the OECD’s global tax reform by introducing the qualified domestic minimum top-up tax (QDMTT), effective from the 2025–26 fiscal year, reinforcing its dedication to international tax transparency and its status as a forward-looking jurisdiction. The QDMTT is a key component of the OECD’s Pil - lar Two initiative, which requires large multinational groups to be subject to a minimum effective tax rate of 15% under the Global Anti-Base Erosion (GloBE) Rules. Mauritius first incorporated the GloBE frame - work through the Finance Act 2022, with detailed implementation provided in the Finance Act 2025, and the QDMTT ensures that any resulting top-up tax is collected domestically rather than by other jurisdic - tions. 9.3 International Tax International tax has an extremely high public profile in Mauritius, as Mauritius has established itself as a plat - form used by foreign investors to invest from foreign jurisdictions. Mauritius is therefore fully collaborative with international institutions and is committed to comply with international obligations and standards. 9.4 Competitive Tax Policy Objectives Despite concerns from the financial sector about potential unfair tax competition, especially with non- OECD countries after BEPS implementation, the gov - ernment of Mauritius remains committed to imple -
benefit from that regime. While there is no word on whether the authorities will take steps to tighten these conditions further or place additional obligations on companies, it remains to be seen if the regime will be revisited. 9.6 Hybrid Instruments and BEPS Implementation Mauritius has reserved its right under the Multilateral Convention to opt out of applying the Article 3, dealing with hybrid mismatch arrangements. 9.7 Interest Deductibility and Territorial Tax Regime Mauritius does not have a territorial tax system; com - panies are taxed on their worldwide income subject to the available credits or double taxation convention (DTC) provisions. 9.8 Controlled Foreign Corporation Reform Mauritius does not have a territorial tax system; no CFC reforms are being proposed. 9.9 Anti-Avoidance Rules The inclusion of a “principal purpose test” provision in relevant tax treaties is likely to impact investors; as such, investors should ensure that they will not be denied any treaty benefits under their particular circumstances. 9.10 Transfer Pricing and IP Taxation Mauritius has not enacted specific transfer pricing rules. 9.11 Country-by-Country Reporting and Transparency Provisions Mauritius participates in country-by-country reporting (CbCR) as part of its broader commitment to uphold international tax transparency standards. By join - ing the BEPS Inclusive Framework in 2016, Mauri - tius committed to implementing the minimum BEPS standards, including CbCR. Mauritius issued the Income Tax (Country by Country Reporting) Regula - tions 2018 on 19 February 2018, with the rules apply - ing to the reporting fiscal years of multinational enter - prise groups beginning on or after 1 July 2018.
menting the BEPS minimum standards. 9.5 The Competitive Tax System
In recent times, increased emphasis has been placed on “substance” in Mauritius. In particular, tax regu - lations have been amended in respect of the partial exemption regime, in as much as additional condi - tions have been placed on companies wishing to
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