Mauritania Cross-Border Tax Guide 2026

Overview — Cross-Border Taxation in Mauritania

Mauritania's cross-border tax rules are governed by the Code Général des Impôts and the OHADA Uniform Act. The Direction Générale des Impôts (DGI) administers international tax matters. Multinational enterprises operating in Mauritania must comply with transfer pricing documentation requirements, thin capitalisation rules, and withholding tax obligations. Non-residents earning Mauritania-source income are generally subject to withholding taxes at statutory rates, which may be reduced under applicable treaties. Mauritania is a member of the Arab League and the African Union and has treaty networks within these frameworks.

Transfer Pricing

Mauritania's transfer pricing rules require that transactions between related parties be priced at arm's length. The rules follow the OECD Transfer Pricing Guidelines. Related parties include companies under common control, parent-subsidiary relationships, and individuals with significant influence. Documentation requirements include a local file with details of related-party transactions. Acceptable transfer pricing methods include the Comparable Uncontrolled Price (CUP) method, Cost Plus method, Resale Price method, and Transactional Net Margin Method (TNMM).

Thin Capitalisation

Mauritania's thin capitalisation rules limit the amount of interest that a company can deduct on related-party debt. Interest on debt exceeding the allowable debt-to-equity ratio (typically 3:1) may be disallowed as a deduction and recharacterised as a dividend for withholding tax purposes. The rules apply to related-party debt including loans from foreign parent companies.

Withholding Taxes to Non-Residents

Payments to non-residents from Mauritania-source income are subject to withholding tax at the following standard rates (treaty rates may apply): dividends 10%, interest 10%, royalties 15%, management and technical fees 20%, and branch profits remittance 10%. The person making the payment must withhold the tax and remit it to DGI within 15 days. Treaty relief requires the non-resident to provide a Certificate of Tax Residency.

Double Tax Treaties

Mauritania has double tax treaties primarily with Arab League countries and certain African nations. Treaties generally follow the OECD or Arab League model tax convention. Treaty benefits include reduced withholding tax rates and potential exemption from CGT on certain assets. To claim treaty benefits, a non-resident must obtain a Certificate of Tax Residency from their home country tax authority and submit a treaty relief application to DGI.

FAQs

Do I need to register for tax in Mauritania as a non-resident investor?

Non-residents earning Mauritania-source income subject to final withholding tax generally do not need to register. However, a non-resident with a permanent establishment must register and file corporate tax returns.

How do I claim a refund of excess WHT?

A non-resident may claim a refund if WHT was deducted at the full statutory rate when a reduced treaty rate should have applied. Submit a refund claim to DGI with supporting documents.

Does Mauritania have a General Anti-Avoidance Rule (GAAR)?

Yes, the Code Général des Impôts includes anti-avoidance provisions that allow DGI to recharacterise transactions entered into for tax avoidance purposes.

Disclaimer

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