A corporation resident in Mauritius is subject to tax on its worldwide income. A non-resident corporation is liable to tax on any Mauritius-source income, subject to any applicable tax treaty provisions.
Corporations are liable to income tax on their net income, currently at a flat rate of 15%. Companies engaged in the export of goods are liable to be taxed at the rate of 3% on the chargeable income attributable to exports based on a prescribed formula.
Mauritius has a credit system of taxation whereby foreign tax credit is given on any foreign-source income declared in Mauritius on which foreign tax of a similar character to Mauritian tax has been imposed.
All corporate bodies incorporated in Mauritius (except 'Authorised Companies' as of 1 January 2019 and certain approved funds and associations) are subject to income tax. Income derived by local partnerships (resident sociétés) is shared and taxed in the hands of the partners. Foreign corporations carrying on business, or having a place of business, in Mauritius are also liable to income tax on income derived from Mauritius.
A société means a société formed under any enactment in Mauritius and includes:
- a société de fait or a société en participation
- a limited partnership
- a joint venture, and
- a société or partnership formed under the law of a foreign country.
Income tax is payable on total net income before distribution at the following rates:
|Global Business Category 1 (GBC1) companies (Global Business Licence as of 1 January 2019) (except for specific income, see below)||15|
|Freeport operators or Private Freeport Developers carrying on Freeport activities other than providing goods and services on local markets||15|
|Global Business Category 2 (GBC2) companies||Exempt|
|Companies engaged in the export of goods||3|
|All other companies||15|
- As of 1 January 2019, GBC1 companies will be renamed as Global Business Licence (GBL) and will be liable to tax at the rate of 15%.
- However, GBL will qualify for an 80% partial exemption in relation to certain specific foreign-source income (e.g. foreign dividend not allowed as deduction in source country, interest income, foreign-source income derived by a Collective Investment Scheme [CIS], closed end funds, 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 from the leasing and provision of international fibre capacity, interest income derived by a person from money lent through a peer-to-peer lending platform operated under a licence issued by the relevant authority after the five-year tax holiday, income derived from reinsurance and reinsurance brokering activities, income derived from the sale, financing arrangement, and asset management of aircraft and its spare parts, including aviation-related advisory services).
- No actual foreign tax credit is allowed on foreign-source income if the GBL company has claimed the 80% partial exemption.
- Freeport companies (excluding local trading activity) shall continue to be exempt from tax until 30 June 2021, subject to the Freeport certificate being issued on or before 14 June 2018.
The maximum effective tax rate is 3% for specific income streams; otherwise, the tax rate is 15%. See below grandfathering provisions for GBC1:
|GBC1 licence issue date||Grandfathering|
|On or before 16 October 2017||Grandfathered up to 30 June 2021|
- As of 1 January 2019, GBC2 licence will be abolished.
- Companies conducting business and having their place of central management outside of Mauritius will be required to apply for an authorisation to the FSC to be registered as an 'Authorised Company'.
- On 30 June 2021, GBC2 licences will lapse, and companies will need to comply with the prescribed requirements of the FSC.
- An Authorised Company will be treated as a non-resident for tax purposes in Mauritius.
- An Authorised Company is required to file a return of income to the MRA within six months of its year-end.
- Transitional period available to GBC2 companies is as follows:
|GBC2 licence issue date||Grandfathering|
|On or before 16 October 2017||Grandfathered up to 30 June 2021|
For more information, see the Tax credits and incentives section.
Taxation of banks
All banks are required to pay a special levy calculated according to their book profit and their operating income derived during the preceding year. 'Operating income' means the sum of net interest income and other income before deducting non-interest expense.
The rates of the special levy on banks are as follows:
|Year of assessment commencing||Rates|
|1 July 2018||1.7% on book profit; |
0.5% on operating income
Except where the levy is computed on chargeable income, no levy shall be paid in a year where in the preceding year:
- the bank incurred a loss, or
- the book profit of the bank did not exceed 5% of its operating income.
The following is also applicable:
- Abolition of the Segment A and Segment B regime effective as from the year of assessment commencing 1 July 2020.
- Banks deriving income from banking transactions with non-residents and GBL companies will still be considered as foreign-source income up to the year of assessment commencing 1 July 2019.
- Income derived by banks from Global Business Companies will not be subject to special levy.
- Income of banks derived from small and medium-sized enterprises (SMEs) in Mauritius, enterprises engaged in agriculture, manufacturing, or production of renewable energy, and from operators in African and Asian countries will be taxed at a reduced rate of 5%.
- Effective from the year of assessment commencing 1 July 2020, banks will no longer be required to submit an auditor’s certificate regarding segmental split of expenses and will be taxed as follows:
|Chargeable income||Tax rate (%)|
|Up to 1.5 billion Mauritian rupees (MUR)||5|
- There are some special provisions in respect of the year of assessment 2017/18, the first year of operations, as well as certain prescribed conditions.
- Where chargeable income of the bank is taxed at 5%, no tax credit is allowed on foreign-source income.
Corporate Social Responsibility (CSR) Fund
Every year, a company has to set up a CSR Fund equivalent to 2% of its chargeable income of the preceding year.
At least 75% of the CSR Fund set up on or after 1 January 2019 should be remitted to the MRA.
In respect of a CSR Fund set up before 1 January 2019, the remaining amount of the CSR Fund shall be used to implement a CSR Programme in accordance with the company's own CSR Framework. For a CSR Fund set up on or after 1 January 2019, the remaining amount shall be used to implement a CSR Programme or finance a non-governmental organisation implementing a CSR Programme in the following priority areas of intervention, amongst others:
- Dealing with health problems.
- Educational support and training.
- Family protection, including gender-based violence.
- Socio-economic development as a means for poverty alleviation.
- Social housing.
- Supporting persons with severe disabilities.
Any amount unspent (in respect of a CSR Programme) shall be remitted to the MRA together with the company's annual return. The amount to be remitted to the MRA could be reduced upon prior written approval from the National CSR Foundation.
No CSR money shall be spent by a company on the following activities:
- Activities discriminating on the basis of race, place of origin, political opinion, colour, creed, or sex.
- Activities targeting shareholders, senior staff, or their family.
- Activities that are against public safety and national interest.
- Religious, political, trade union, staff welfare and training of employees, and marketing activities.
Where the amount paid out of the CSR Fund is in excess to the amount provided for under that CSR Fund, such excess may be carried forward and offset in equal instalments against any amount to be remitted to the MRA in respect of five succeeding years starting from year of assessment 2016/17.
Where a company is required to submit an Advance Payment System (APS) statement, it should remit 75% of the CSR amount to be remitted to the MRA together with the APS statements, and the final 25% is to be remitted on the submission of the final return.
Local income taxes
Local income taxes levied by local administration, such as urban councils, do not exist in Mauritius.