Mauritius: An Overview

Background

Mauritius is strategically located in the Indian Ocean, at the crossroads of global trade and investment flows. It offers excellent connectivity and access to key markets. Its geographic proximity and strong cultural and economic ties to both Africa and Asia make it an ideal gateway for investors targeting emerging markets in these regions. The jurisdiction offers an investor-friendly environment and investment ecosystem, underpinned by its recognition as an “international financial centre”, a sophisticated legal and regulatory framework, a highly skilled professional services sector and a modern, robust and internationally aligned tax system. Key fiscal advantages include the non-taxation of capital gains and dividend distributions, no foreign exchange controls, and unrestricted repatriation of profits. Mauritius benefits from a stable political environment and a supportive government that actively promotes business growth. On a yearly basis, the government devises and implements various initiatives to attract foreign investment, foster economic development and stimulate entrepreneurship. These pro-business policies, coupled with a strong commitment to maintaining political stability, create a conducive and safe environment for investors to thrive and expand operations.

Legal Framework

Mauritius has a hybrid legal system that combines both civil and common law practices. It is governed by principles drawn from both the French Napoleonic Code and English common law.

The Supreme Court is the highest judicial authority in Mauritius and has unlimited jurisdiction to hear any criminal and civil proceedings. Mauritius has retained the Judicial Committee of the Privy Council of the United Kingdom as its final court of appeal. Mauritius is also becoming an increasingly attractive forum for international arbitration, reinforcing its reputation as a reliable and investor-friendly jurisdiction for cross-border business.

Economic Overview

Mauritius has concluded 46 double taxation avoidance agreements, with another seven awaiting ratification, six additional ones awaiting signature, and a further 20 currently being negotiated. Mauritius is also a party to 28 Investment Promotion and Protection Agreements, with another 16 awaiting ratification and a further 20 currently being negotiated. The participation of Mauritius in these treaties provides extra assurance and security for its potential investors. In fact, the extensive and expanding offering from Mauritius confirms the country’s position as a tax-efficient jurisdiction for structuring investments.

The jurisdiction’s financial sector continues to thrive, with Mauritius ranking first in Africa in the Global Financial Centres Index (GFCI 38).

Latest Developments in Mauritius

Qualified domestic minimum top-up tax (QDMTT)

The government has introduced a QDMTT in line with the Organisation for Economic Co-operation and Development’s (OECD) Pillar Two global minimum tax rules. QDMTT applies to every person who is a member of a multinational enterprise group which has an annual 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 preceding the fiscal year for which the QDMTT is leviable. From 1 July 2025, every covered person will be liable to QDMTT for a fiscal year where the combined effective tax rate determined for all covered persons in that fiscal year is less than 15%. This regime ensures that large multinational groups pay a minimum level of tax on income generated in each jurisdiction where they operate.

Fair share contribution (FSC)

A transitional FSC has been introduced for the period from 1 July 2025 and for the subsequent two income years. Under this measure, every company, other than a bank, having supplies exceeding MUR24 million in an accounting year or that is required to be registered under the Value Added Tax Act, and chargeable income exceeding MUR24 million in an accounting year, must pay to the Mauritius Revenue Authority an FSC of 5% or 2%, as applicable, of its chargeable income. Banks must pay an FSC of 5%, plus an additional FSC equivalent to 2.5% of their chargeable income arising from transactions with residents, other than from a global business entity. The FSC does not apply to global business companies.

Alternative minimum tax (AMT)

From a year of assessment commencing on 1 July 2026, an AMT will apply to companies operating in certain sectors, including hotels, insurance, financial intermediaries, real estate and telecommunications. Where, in the case of a company other than a global business entity, the normal tax payable is less than 10% of its adjusted book profit in an income year, the tax payable for that income year will be deemed to be 10% of the adjusted book profit.

Lower VAT registration threshold

Businesses are now required to register for VAT upon making a turnover of taxable supplies exceeding MUR3 million instead of MUR6 million.

VAT on digital/electronic services

Specified digital or electronic services provided by foreign suppliers will be subject to VAT in Mauritius from 1 January 2026, irrespective of their turnover of taxable supplies. The services in scope include, among others:

• website supply or web-hosting services;
• advertising space on a website;
• online magazines; and
• distance maintenance of programmes and equipment.

Registration duty and land transfer tax

From 1 July 2026, the registration duty for non-citizens acquiring residential property under an EDB Property Scheme or the Non-Citizens (Property Restriction) Act will increase from 5% to 10%. Similarly, land transfer tax will rise to 10% for such acquisitions.

Competition law development

The competition law framework has been amended to empower the Competition Commission to conduct market inquiries, with similar powers to gather information as for its investigations. These inquiries will help identify and address wider competition issues that stem from market features, including the structure, regulatory environment and general conduct of operators. Although this heightened scrutiny may place additional demands on market participants, the measure is expected to deter anti-competitive behaviour and foster a more accessible and competitive environment for emerging and mid-sized enterprises.

Share transfers under the Financial Services Act

An issue or a transfer of shares or legal or beneficial interest of less than 5% in a licensee or

to an existing shareholder – unless such issue or transfer results in a change in control in the licensee – will no longer require the approval of the Financial Services Commission of Mauritius.

By maintaining a strategic focus on innovation, sustainability and inclusive growth, Mauritius continues to strengthen its tax and regulatory framework, ensuring that it remains a stable, secure and forward-looking destination for both regional and international investment.