MAURITIUS Law and Practice Contributed by: Bhavna Ramsurun, Pinki Mahata, Lorna Senivassen and Shreya Mungur, BLC Robert & Associates
• if the investor is an individual, the chargeable income of the investor will be subject to a progressive tax ranging from 0% to 20%. Further, a tax-resident investor may be subject to a corporate climate responsibility levy of 2% on its chargeable income in respect of each year of assessment (first year commencing on 1 July 2024) where their turnover for that year of assessment exceeds MUR50 million. A tax-resident investor that is a body corpo - rate will be entitled to benefit from the Foreign Tax Credit or as a partial exemption of 80% in respect of the following types of income: • foreign source dividend, provided that such dividend is not allowed as a tax-deductible item in the source country and the company satisfies the conditions relating to the sub - stance of its activities as prescribed; • interest derived by a company (other than a bank referred to in Section 44C of the ITA, a non-bank deposit-taking institution, a money changer, a foreign exchange dealer, an insurance company, a leasing company, or a company providing factoring, hire purchase facilities or credit sales facilities) – provided that the company satisfies the conditions relating to the substance of its activities as prescribed; • profit attributable to a permanent establish - ment held by a resident company in a foreign country; • income derived by a CIS, CEF, CIS manager, CIS administrator, investment adviser or asset manager licensed or approved by the FSC; • income derived by companies engaged in ship and aircraft leasing; • income derived by a company from reinsur - ance and reinsurance brokering activities, subject to satisfying any conditions pre -
scribed relating to the substance of its activi - ties; • income derived by a company from the leasing and provision of international fibre capacity, subject to satisfying any conditions prescribed relating to the substance of its activities; • interest derived by a person from money lent through a peer-to-peer lending platform; and • income derived by a company from the sale, financing arrangement, and asset manage - ment of an aircraft and its spare parts (and the provision of aviation advisory services related thereto), subject to satisfying any pre - scribed conditions relating to the substance of its activities. A tax-resident investor who is an individual will be entitled to: • Foreign Tax Credit; • deduct the applicable amount of personal reliefs and deductions from their net income in each income year; and • any other reliefs, allowances and deductions as apply. Any dividend income received or gains made by any Mauritian investor from a fund established as a company in Mauritius are exempt from income tax.
3. Retail Funds 3.1 Fund Formation 3.1.1 Fund Structures
Retail funds can be set up as companies, lim - ited partnerships, PCCs, trusts or VCCs, as described in 2.1.1 Fund Structures .
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