Madagascar Tax Residency Guide 2026

Overview — Tax Residency in Madagascar

Tax residency is the foundational concept determining the scope of taxation in Madagascar. Resident individuals are taxed on their worldwide income; non-residents are taxed only on Madagascar-source income. Residency is defined under the General Tax Code (Code Général des Impôts). For individuals, the test is primarily based on physical presence (183 days) or having a permanent home in Madagascar. For companies, residency follows incorporation or place of effective management. The Direction Générale des Impôts (DGI) applies these rules consistently and may challenge arrangements designed to artificially avoid residency status.

Individual Residency — 183-Day Rule

An individual is considered a tax resident of Madagascar if they meet any of the following conditions:

• Physical presence — present in Madagascar for 183 days or more in a calendar year
• Permanent home — has a permanent home available in Madagascar (whether owned or rented)
• Centre of vital interests — Madagascar is the place where the individual's primary economic and personal interests are located
• Habitual abode — has a habitual place of abode in Madagascar and is present for any period during the year

Day counting includes both partial days and full days. A person who enters Madagascar on day 1 and leaves on day 183 counts as present for 183 days. The 183-day test applies to the calendar year (January to December). Expats working in Madagascar should track their presence carefully. The tax administration may also use the centre of vital interests test for individuals who spend fewer than 183 days but have stronger economic ties to Madagascar than to any other country.

Corporate Residency

A company is tax resident in Madagascar if either of the following conditions is met:

• Incorporation — the company is incorporated or registered under Malagasy company law (in accordance with the Uniform Act on Commercial Companies, OHADA)
• Effective management — the place of effective management (POEM) of the company is in Madagascar (where key management and commercial decisions are made)

Foreign companies that have their central management and control exercised in Madagascar may be deemed resident regardless of where they are incorporated. The POEM test follows OECD guidance and considers factors such as the location of board meetings, where the CEO and senior executives operate, and where strategic decisions are made. A foreign-incorporated company that manages its affairs from Madagascar is at risk of being treated as resident. Companies registered under the OHADA Uniform Act in Madagascar are automatically considered resident.

Source Rules — Madagascar-Source Income

Non-residents are taxed only on income derived from sources in Madagascar. The General Tax Code defines specific source rules:

• Employment income — sourced where the employment duties are performed (physical location)
• Business income — sourced where the business activities are carried out (or through a permanent establishment in Madagascar)
• Property income — sourced where the property is located (rental, capital gains on Malagasy property)
• Dividends — sourced where the paying company is resident
• Interest — sourced where the payer is resident (including Central Bank and government)
• Royalties — sourced where the intellectual property is used

Income sourced in Madagascar by a non-resident is subject to withholding tax at the applicable rate, which may be reduced under a double tax treaty.

Double Tax Treaties (DTTs)

Madagascar has a network of double tax treaties, primarily with Francophone and neighbouring countries. As of 2026, Madagascar has signed comprehensive DTTs including with:

• France — 10% dividend rate (15% if <10% shareholding), 10% interest, 10% royalties
• Mauritius — 5% dividend (≥10% shareholding), 10% interest
• South Africa — 5% dividend (≥10% shareholding), 8% interest
• Switzerland — 5% dividend (≥25% shareholding), 10% interest
• Belgium — 10% dividend, 10% interest
• Canada — 5% dividend (≥10% shareholding), 15% interest
• Norway — 5% dividend (≥25% shareholding), 10% interest

Treaties generally reduce withholding tax rates on dividends, interest, and royalties paid to residents of treaty countries. To claim treaty benefits, the recipient must provide a Certificate of Tax Residency from their home country and submit a treaty relief application to DGI. Madagascar follows the OECD Model Tax Convention for most of its treaties. Negotiations are ongoing with several other countries to expand the treaty network.

FAQs

If I work remotely for a foreign company while in Madagascar, am I taxable?

If you are physically present in Madagascar for 183+ days in a calendar year, you are a tax resident and must declare your worldwide income, including salary from foreign employment. If present for fewer than 183 days, only Madagascar-source income is taxable.

How do I prove I am not a resident for DGI purposes?

Maintain records of travel dates, visa stamps, employment contracts, rental agreements, and tax returns from your home country. A Certificate of Tax Residency from your home country is strong evidence of non-residency.

Can I be resident in two countries at once?

Yes, dual residency is possible. The applicable double tax treaty will contain a tie-breaker clause (permanent home, centre of vital interests, habitual abode, nationality) to determine which country has primary taxing rights.

Disclaimer

This guide provides general information about Malagasy tax residency for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Malagasy tax advisor or the Direction Générale des Impôts for advice specific to your situation. InvestmentKit does not provide tax advice.