MAURITIUS Law and Practice Contributed by: Sameer K Tegally, Sonia Xavier and Ashvan Luckraz, Venture Law
Partial Exemption for Virtual Asset Service Providers (VASPs) Licensed virtual asset service providers shall be eligible to claim an 80% partial exemption on income derived from virtual asset-related activi - ties, subject to compliance with prescribed eco - nomic substance requirements. Restriction on Exemption for Banks Banks shall no longer be entitled to the 80% partial exemption in respect of foreign-source dividend income. 5.4 Tax Consolidation There are no group taxation provisions in the Mauritian tax legislation other than the trans - fer of losses by tax incentive companies, sugar factory operators, subsidiaries in Rodrigues and manufacturing companies upon their takeover. 5.5 Thin Capitalisation Rules and Other Limitations Mauritius does not have specific thin capitali - sation legislation; however, it does have other anti-avoidance provisions, as described below. If a company has issued debentures to each of its shareholders, subject to the number, the nominal value, or paid-up value of the shares in that company, any interest paid on debentures and claimed as a deductible expense may be disallowed and treated as a dividend. 5.6 Transfer Pricing Mauritius does not have any specific transfer pricing legislation. However, it does contain an arm’s-length provision requiring transactions between related parties to reflect a commercial - ly objective value, which would be the amount charged for the services were the parties not connected.
• payments to contractors and subcontractors – 0.75%; and • payments to providers of services (account - ant/accounting firm, architect, attorney/solici - tor, barrister, dentist, doctor, engineer, land surveyor, legal consultant, project manager in the construction industry, quantity surveyor, property valuer, and tax adviser or represent - ative) – 3%. 5.3 Available Tax Credits/Incentives Mauritius has a credit system of taxation where - by foreign tax credit is given on any foreign- source income declared in Mauritius on which foreign tax of a similar character to Mauritian tax has been imposed. No actual foreign tax credit is allowed on for - eign-source income derived from a corporation issued with a Global Business Licence on or before 16 October 2017, if they have claimed the 80% exemption. Pursuant to the measures announced in the 2025–2026 Budget, the government intends to introduce the amendments outlined below. Tax Credit for Small Businesses Small enterprises with an annual turnover not exceeding MUR10 million shall be entitled to a tax credit of 5% per annum, for a period of three consecutive years (aggregating to 15%), in respect of capital expenditure incurred on the acquisition of new equipment, up to a maximum of MUR500,000 per year. This incentive shall exclude expenditure on motor vehicles. Any unutilised tax credit may be carried forward for a period not exceeding five years.
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