MAURITIUS Law and Practice Contributed by: Johanne Hague, Gaelle Angoh Li Ying Pin, Medina Torabally and Béatrice Phanjoo, CMS Prism in association with CMS
subject to confidentiality safeguards. Mauritius has 11 TIEAs in force as at February 2026. 5.5 Role of Tax Authorities and Enforcement Measures In cases of suspected fraud or evasion, the MRA is empowered to investigate and request information from an individual or company. This includes site vis - its, access to records and collection of documents after formal requests. In this context, the MRA is not limited by the usual three-year timeframe to conduct audits and raise assessments. The Fiscal Investiga - tions Department of the MRA is further able to con - duct investigations into potential tax evasion cases, to collect evidence and recommend prosecution for offences. Additionally, the Legal Services Department of the MRA can conduct inquiries with similar powers to those of police officers and lodge a case before the competent court of Mauritius. The MRA is vested with the statutory power to conduct any audit on a taxpayer’s affairs and raise assessments where the MRA is not satisfied with the return filed by a taxpayer. It may revise the tax return of the taxpayer and impose an additional tax liability together with administrative penalties and interests. In its SOP on ‘Imposition of Assessing Penalty’ (SP 13/16), the MRA provides a comprehensive method by which such penalties are calculated. The MRA may impose an assessing penalty of 50% where it con - cludes that there has been a tax fraud. 6.2 Criminal Penalties 6. Penalties and Sanctions 6.1 Tax Penalties Tax evasion, which is treated as a criminal offence under the ITA 1995, will be subject to criminal pro - ceedings and attract penalties as well as imprison - ment terms. The Mauritian case law, however, does not include many convictions in relation to tax eva - sion. Tax fraud usually would not lead to prosecution per se. In cases of suspected tax fraud, the MRA will con - duct audits to consider whether there has been an understated tax liability. In the affirmative, the MRA
will reassess the tax liability and impose high penal - ties and interest. 6.3 Interaction Between Tax and Criminal Procedures Criminal proceedings usually start once the civil tax matter has been concluded or upon recommendation from the Fiscal Investigations Department of the MRA after completion of its inquiry. Where the facts indicate a wider financial crime dimen - sion, the MRA can co-ordinate with other regulatory authorities in Mauritius, including in cases where tax evasion is investigated alongside money laundering. 7. Administrative Co-Operation 7.1 Legal Framework for Administrative Co- Operation Mauritius is a member of the OECD G20 Inclusive Framework on BEPS and has ratified the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, which supports multilateral administra - tive co-operation. The country is also compliant with EU recommendations. Mauritius also has an extensive network of double taxation avoidance agreements (DTAAs) that cater for co-operation between competent authorities of the contracting states. 7.2 Exchange of Information Clauses in Tax Agreements Mauritius participates in the automatic exchange of information as a signatory to the CRS and under FATCA. Mauritius has also implemented Country-by-Country Reporting in accordance with BEPS Action 13. Mauritius currently has TIEAs with 11 countries. 7.3 Other Forms of International Tax Collaboration Mauritius participates in several multilateral tax arrangements beyond mutual agreement procedures/ advance pricing agreements, notably as a signatory
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