The main sources of international tax law in Mauritius are domestic law, public international law and judicial precedents.

Primary Mauritian Legislation

The principal source of domestic tax law is the Income Tax Act 1995 (“ITA 1995”).

Subsidiary Legislation

Regulations made by the Minister of Finance pursuant to Section 161 of the ITA 1995 have the force of law. The main sources of legislation for tax purposes include:

• the Income Tax Regulations 1996;
• the Income Tax (Foreign Tax Credit) Regulations 1996;
• the Income Tax (Negative Income Tax Allowance) Regulations 2017; and
• the Income Tax (Financial Assistance) Payment Special Allowance Regulations 2025.

International instruments

Mauritius follows a dualist approach: tax treaties and other international agreements have no direct effect in domestic law unless and until they are expressly incorporated and duly ratified. Once so incorporated and ratified, they have the force of law. More notably, Mauritius is a party to the Vienna Convention on the Law of Treaties of 1969 and has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting.

Mauritius has developed an extensive treaty network with African, Asian and European jurisdictions. As at February 2026, Mauritius has concluded 46 tax treaties. There are seven treaties pending ratification; seven more await signature and 19 are being negotiated.

Beyond tax treaties, Mauritius participates in information exchange and mutual administrative assistance networks (eg, arrangements for automatic exchange of financial account information), which reinforce international transparency and compliance standards.

Jurisprudence

Case law is an important source of law in tax disputes before the Revenue Tribunal and the Supreme Court of Mauritius. Where there is limited local jurisprudence on specific concepts, the courts may seek persuasive guidance from Commonwealth authorities – principally the United Kingdom and New Zealand, given the similarities of their legislation to the ITA 1995. Domestic jurisprudence, however, has limited bearing on the interpretation of tax treaty provisions.

Tax administration

The Mauritius Revenue Authority (MRA) is the statutory body established under the Mauritius Revenue Authority Act 2004 to administer and enforce the revenue laws of Mauritius, including the assessment and collection of taxes under the ITA 1995.

Tax rulings

A taxpayer may apply to the Director-General (DG) of the MRA for a ruling in relation to a transaction. The DG must issue the ruling within 30 days of receipt of the application. Such ruling is binding on the MRA (but not on the courts), except where there is a material difference in the facts.

Statements of Practice and guidance

Pursuant to Section 159A of the ITA 1995, the MRA issues Statements of Practice (SOPs) on the application of legal provisions. The MRA also issues communiqués and guidance notes to clarify aspects of the tax legislation. SOPs and guidance notes are persuasive in nature and are not binding on a court of law.

International tax rules do not apply automatically in Mauritius until they are expressly incorporated and ratified into Mauritian law and operate with the force of law.

Matters not governed by an applicable treaty remain subject to domestic tax law. Where both domestic law and an incorporated treaty purport to apply to the same subject matter, the treaty (as implemented in Mauritian law) prevails to the extent of any inconsistency.

Mauritius broadly follows the recognised OECD model of taxation, and the tax treaties are generally drafted in compliance with OECD rules. Where the treaties are not modified by the Multilateral Instrument (MLI), the country uses bilateral protocols, for instance with India.

Mauritius is a signatory to the MLI, which was signed on 5 July 2017 and ratified on 18 October 2019. The MLI entered into force on 1 February 2020. Mauritius has listed 44 of its 46 tax treaties as Covered Tax Agreements, which, once modified, incorporate the base erosion and profit shifting (BEPS) minimum standards, with the principal purpose test as the main anti‑abuse provision.

For individuals, Mauritius applies a mixed source and remittance regime. Income derived from within Mauritius is chargeable regardless of the taxpayer’s residence status, and foreign-source income is chargeable only when remitted to the country by a Mauritian resident.

Resident companies are subject to corporate income tax on their worldwide chargeable income at a rate of 15%, subject to any applicable exemption or credits available. Additional taxes may be imposed based on the turnover of the company – see 3.2 Business Profits.

All taxes in Mauritius are administered under a unified tax system at the national level. Mauritius does not operate any separate regime for islands other than the main island.

Tax residence of individuals is determined according to one of the three criteria below, depending on whether an individual:

• (i) has their domicile in Mauritius, unless their permanent place of abode is outside Mauritius;
• (ii) has been present in Mauritius in that income year, for a period of, or an aggregate period of, 183 days or more; or
• (iii) has been present in Mauritius in that income year and the two preceding income years, for an aggregate period of 270 days or more.

A person will be considered tax resident in Mauritius in any income year if one of those criteria is met save for (iii) above, in which case tax residence takes effect prospectively as from the third income year.

An individual who is tax resident in Mauritius is taxed on all Mauritius-source income, other than exempt income, derived by them during the preceding income year. They are taxed on foreign source only if it is remitted to Mauritius.

Definition of Income

Income for the purposes of the ITA 1995 includes:

• any advantage in money or in money’s worth such as salary, wages, leave pay, fee, overtime pay, perquisite, allowance, bonus, gratuity, commission or other reward or remuneration in respect of or in relation to the office or employment of that individual, any superannuation, compensation for loss of office, pension, retiring allowance, annuity or other reward in respect of or in relation to past employment or loss or reduction of future income of that individual, whether receivable by that individual or by any person who is or has been the spouse or dependant of that individual;
• any gross income derived from any business;
• any rent, royalty, premium or other income derived from property;
• any dividend, interest, charges, annuity or pension;
• basic retirement pension payable under the National Pensions Act 1976;
• any gross income, in money or money’s worth, derived from the sale of immovable property in the course of any business; and
• any other income derived from any other source.

Income Tax Bands

As from the income year beginning on 1 July 2025, the Mauritius personal income tax regime provides for three tax bands, with the lowest bracket of income (up to MUR500,000 per annum) having a tax rate of 0%. The second bracket (MUR500,001–MUR1 million) attracts a rate of 10%. The highest bracket (above MUR1 million) is subject to a tax rate of 20%.

Fair Share Contribution

Individuals with a total annual income (including local dividends, which are usually exempt) exceeding MUR12 million in an income year are also liable to a “Fair Share Contribution” of 15% on the leviable income in excess of MUR12 million. This is payable at the time of the filing by the individual of their return of income. Dividends or distributions received from entities holding a global business licence, as well as from a foundation or a trust are, however, excluded from the total income considered.

Deductions

Personal reliefs, deductions and allowances under the ITA 1995 can only be claimed by resident individuals in an income year. Deductions can also be claimed in relation to an individual’s dependants.

Exempt income is listed in the Third Schedule to the ITA 1995 and include, inter alia, dividends paid by a resident company.

Estate, Inheritance and Gift Taxes

There is no inheritance, succession, estate, donation or gift tax in Mauritius.

A non-resident is only taxable on all Mauritius-source income, other than exempt income. The types of income are addressed in 2.3 Taxation of Resident Individuals.       

The rule of tax residence for companies in Mauritius is determined based on the company’s incorporation in Mauritius or the location of the company’s central management and control.

A company is considered tax resident in Mauritius if:

• it is incorporated in Mauritius; or
• its central management and control are in Mauritius.

However, Section 73A of the ITA 1995 provides that a company incorporated in Mauritius, but centrally managed and controlled outside of Mauritius, may be deemed to be non-resident for tax purposes.

For Mauritius tax purposes, trusts and foundations are treated as companies (other than charitable trusts or foundations).

A trust is treated as tax resident:

• where the trust is administered in Mauritius and a majority of the trustees are resident in Mauritius; or
• where the settlor of the trust was resident in Mauritius at the time the instrument creating the trust was executed.

A foundation, on the other hand, is deemed resident:

• where it is registered in Mauritius; or
• where it has its central management and control in Mauritius.

Pursuant to the MRA’s SOP 24/21 on trusts and foundations, a trust or foundation set up in Mauritius is treated as non-resident if it is centrally managed and controlled outside Mauritius. Central management and control is determined as follows:

• For trusts:
1. the trust is administered in Mauritius and a majority of the trustees are resident in Mauritius;
2. the settlor of the trust was resident in Mauritius at the time the instrument creating the trust was executed or at such time as the settlor adds new property to the trust; and
3. a majority of the beneficiaries or class of beneficiaries appointed under the terms of the trust are resident in Mauritius.
• For foundations:
1. the founder is resident in Mauritius; and
2. a majority of the beneficiaries appointed under the terms of a charter are resident in Mauritius.

The ITA 1995 only defines a permanent establishment for the purposes of the qualified domestic minimum top-up tax (QDMTT) provisions, which are duly aligned with the OECD Model Tax Convention on Income and on Capital, as:

• (a) a place of business situated in a jurisdiction and treated as a permanent establishment in accordance with an applicable tax treaty in force, provided that such jurisdiction taxes the income attributable to it in accordance with a provision similar to Article 7 of the OECD Model Tax Convention;
• (b) if there is no applicable tax treaty in force, a place of business in respect of which a jurisdiction taxes under its domestic law the income attributable to such place of business on a net basis similar to the manner in which it taxes its own tax residents;
• (c) if a jurisdiction has no corporate income tax system, a place of business situated in that jurisdiction that would be treated as a permanent establishment in accordance with the OECD Model Tax Convention provided that such jurisdiction would have had the right to tax the income attributable to it in accordance with Article 7 of that Convention; or
• (d) a place of business that is not already described in paragraphs (a) to (c) above through which operations are conducted outside the jurisdiction where the entity is located provided that such jurisdiction exempts the income attributable to such operations.

Although the ITA 1995 does not contain a general definition of permanent establishment beyond the QDMTT provisions as provided above, the MRA would typically rely on Section 74 of the ITA 1995 to assert whether a foreign company has a taxable presence where it is carrying on business wholly or partly in Mauritius.

From a treaty perspective, most treaties generally define a permanent establishment as “a fixed place of business through which the business of the enterprise is wholly or partly carried on”. The definition is further typically supplemented by an enumerated, non‑exhaustive list of inclusions. For instance, the Mauritius–South Africa treaty, under Article 5, provides that permanent establishment includes, inter alia, a place of management, branch, office, factory, workshop, or site of natural‑resource extraction, and the same is followed by express exclusions for activities such as use of facilities solely for the purpose of storage, display or delivery of goods.

Rental income from immovable property located in Mauritius is deemed to be Mauritius-source income and is subject to income tax regardless of whether it is received by a resident or a non-resident.

Rental income paid by any person other than an individual is also subject to Tax Deduction at Source (TDS) at a rate of 7.5% for residents and 10% for non-residents.

TDS is applicable when the rental payment exceeds MUR500 per transaction. Generally, payments made by individuals are not subject to TDS unless the rental is for business purposes.

Sales of immovable property undertaken in the course of business will be tantamount to the income derived from such sale being generally taxable at the rate of 15%. However, a sale of immovable property not undertaken as trade shall not attract any tax inasmuch as capital gains are not taxable in Mauritius.

Resident companies are generally subject to the headline rate of 15% on their worldwide chargeable income subject to any credits or exemptions that may be applicable. The chargeable income is defined as net income, which is the amount remaining after allowable deductions from the gross income.

Exemptions and deductions may be applicable depending on the type of income or activity. For instance, companies involved in the import and export of goods are subject to a reduced rate of tax of 3%. Certain incentivised sectors also benefit from tax holidays.

Specific partial exemptions are also applicable to designated types of income such as foreign dividends or interest income subject to substance requirements being met.

Fair Share Contribution

The Fair Share Contribution (FSC) was introduced in the ITA 1995 in August 2025 and is applicable to companies having a turnover exceeding MUR24 million, and is applicable as from the year starting 1 July 2025 up until 30 June 2028. The FSC, however, does not apply to companies holding a global business licence in Mauritius nor to companies benefiting from tax holidays.

Corporate Social Responsibility Fund

Companies are required, in every year, to set up a corporate social responsibility (CSR) fund equivalent to 2% of their chargeable income in the preceding year. For CSR funds set up on or after 1 January 2019, 75% of the fund must be remitted to the DG of the MRA. For CSR funds set up prior to this, at least 50% should be remitted.

CSR is not applicable to companies holding a global business licence issued by the Financial Services Commission.

Corporate Climate Responsibility Levy

Companies and sociétés (partnerships) that have a turnover above MUR50 million are subject to a 2% corporate climate responsibility levy on their chargeable income. In addition, companies are required to set up a corporate social responsibility fund equivalent to 2% of their chargeable income in the preceding year.