MAURITIUS Law and Practice Contributed by: Sameer K. Tegally, Sonia Xavier and Ashvan Luckraz, Venture Law
Société Resident société
Corporate Social Responsibility (CSR) Every year, a company has to set up a CSR fund equivalent to 2% of its chargeable income of the pre - ceding year. For CSR funds set up on or after 1 Janu - ary 2026, the proportion required to be remitted to the MRA has been reduced to 50%, with the remaining 50% available for CSR implementation, reflecting a more flexible regime while maintaining a mandatory State contribution. VAT VAT shall be charged at the standard rate of 15% on all taxable goods and services, except certain food items that are zero-rated. A person who makes taxable sup - plies in the course of their business and whose annual turnover exceeds or is likely to exceed MUR6 million is required to register for VAT on a compulsory basis. Following the measures announced in the 2025–26 Budget, the government proposes to amend the applicable legislation to reduce the threshold for man - datory VAT registration from MUR6 million to MUR3 million in annual turnover, with effect from 1 Octo - ber 2025. Additionally, certain service providers (eg, accountants and auditors, attorneys and solicitors, consultants, surveyors, valuers) must be VAT regis - tered irrespective of their turnover. The Finance Act introduced the arm’s-length principle to VAT. The reverse charge provision on supply of ser - vices received from abroad has been amended such that it is now applicable only if: • the taxable supply performed or utilised in Mauri - tius is made by a person who does not belong in Mauritius and is not VAT registered; and • the recipient of the supply is a VAT-registered per - son. The supply of digital or electronic services by a foreign supplier to a person in Mauritius will be subject to VAT. Where a VAT-registered person is engaged in a pro - ject spanning several years and the MRA is of the opinion that the apportionment of input tax between taxable supplies and exempt supplies on a prorated basis is not appropriate, it may require the registered
A resident société is not liable to tax. Instead, every associate of the société is liable to tax on his/her share of income, whether distributed or not. Non-resident société A non-resident société shall be liable to income tax as if the société were a company and shall pay income tax on its chargeable income at a rate of 15%. Companies Holding a GBL GBL-holding companies are taxed at the normal rate of 15%, except for an income tax exemption of 80%, which applies to foreign dividends, foreign-source interest income, profit attributable to a permanent establishment of a resident company in a foreign company, foreign-source income derived from a CIS, closed-end funds, CIS managers, CIS administrators, investment advisers or asset managers licensed or approved by the FSC and income derived by compa - nies engaged in ship and aircraft leasing. Qualified Domestic Minimum Top-up Tax (QDMTT) The QDMTT has been introduced in Mauritius effec - tive from the year of assessment commencing on 1 July 2025. The QDMTT is applicable to Mauritius resi - dent entities forming part of a multinational enterprise (MNE group) with a minimum annual consolidated rev - enue of EUR750 million or more in at least two of the last four fiscal years. Every member of an in-scope MNE group shall pay QDMTT where the combined effective tax rate for group members in Mauritius is less than 15%. The QDMTT return and payment will be due within 15 months from the end of the fiscal year. Each relevant resident company must notify the MRA of the designated Mauritius resident person respon - sible for the filing of the QDMTT return. This notifica - tion is due within six months from the end of the MNE group’s fiscal year. Investment funds, pension funds and real estate investment vehicles, amongst others, are excluded from the QDMTT regime.
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