MAURITIUS Law and Practice Contributed by: Johanne Hague, Gaelle Angoh Li Ying Pin, Medina Torabally and Béatrice Phanjoo, CMS Prism in association with CMS
Premium Visa In a bid to encourage foreign nationals to have a digital nomad lifestyle in Mauritius, the Government of Mau- ritius introduced the Premium Visa in 2020. This visa enables non-citizens to stay in Mauritius for a period exceeding six months up to one year, with an option to renew. Where an individual holding a Premium Visa derives income from work performed remotely from Mauritius, that income is deemed to be derived by them in Mau - ritius when it is remitted in Mauritius. Money spent in Mauritius via foreign credit or debit cards will not be considered to have been remitted in Mauritius and will not be subject to tax in Mauritius. 3.6 Other Income No specific types of income other than those listed above are subject to special taxation rules. 4. OECD/G20 Global Tax Reform 4.1 Pillar One – Amount B Mauritius is an active member of the OECD/G20 Inclu - sive Framework on BEPS and intends to implement the two-pillar solution. Pillar One is yet to be directly implemented in Mauritius. 4.2 Pillar One – Amount A Mauritius has not implemented Pillar One Amount A. However, it remains committed to actively participat - ing in the OECD/G20 Inclusive Framework on BEPS and is aligning its tax legislation with international standards. It is not primarily focusing on the adoption of Pillar, as explained below. 4.3 Pillar Two Following amendments made to the ITA 1995 in 2025, Mauritius implemented the QDMTT in line with the OECD’s Pillar Two framework. The QDMTT will be applicable to every person who is a member of a multi - national enterprise group with an annual consolidated revenue of EUR750 million or more in the consolidated financial statements of the ultimate parent entity in at least two of the four fiscal years immediately preced - ing the fiscal year in which the QDMTT is leviable, as from the year of assessment 2025/2026. However,
carrying on business in Mauritius. This rate applies unless reduced or exempted under any tax treaty. Royalties Royalties are taxed at 15%. Royalties paid to residents are subject to WHT at the rate of 10%, while those paid to non-residents are subject to a rate of 15%. However, there is no WHT on royalties paid by a company out of its foreign-source income to a non-resident. Treaties may provide for specific provisions for taxing royalties. The ITA 1995 also provides that interests, rents, roy - alties, compensations and other amounts paid by a special purpose fund to a non-resident shall bear no WHT. 3.4 Capital Gains There is no capital gains tax levied in Mauritius. 3.5 Employment Income Pay As You Earn Employment income is taxed under the pay-as-you- earn (PAYE) withholding system, whereby employers are required to withhold tax from emoluments when paid to employees and remit the tax to the MRA on a monthly basis. Employees can claim personal reliefs and deductions subject to the provisions of the ITA 1995 in respect to each income year by submitting an Employee Declaration Form to the MRA. Pursuant to the First Schedule to the ITA 1995, tax is levied on remuneration as follows: • the first MUR500,000 attracts a rate of 0%; • the next MUR500,000 attracts a rate of 10%; and • the remainder attracts a rate of 20%. Cross-Border Employment Emoluments are treated as Mauritius‑source where they arise from an employment, the duties of which are performed wholly or mainly in Mauritius, irrespec - tive of whether such emoluments are received in Mau - ritius or not.
288 CHAMBERS.COM
Powered by FlippingBook