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Mauritius Cross-Border Tax Guide 2026

Mauritius has a highly attractive cross-border tax regime. No withholding tax on dividends paid to non-residents, 15% WHT on interest and royalties (reduced under DTTs), over 45 double taxation treaties, transfer pricing rules aligned with OECD BEPS, and the GBL 1 regime offering an effective 3% tax rate on foreign-source income.

Overview — Cross-Border Taxation

Mauritius is a premier jurisdiction for cross-border investment and international business structuring. The combination of a flat 15% corporate tax rate, an extensive DTT network, no CGT, no WHT on dividends, and the GBL regime with deemed Foreign Tax Credit makes Mauritius a competitive gateway for investment into Africa, Asia, and beyond. The legal framework is based on English common law and French civil code, providing legal certainty for international investors.

Withholding Tax Rates

Mauritius imposes withholding tax (WHT) on certain payments to non-residents, but at competitive rates:

  • Dividends: 0% to non-residents (no WHT on outbound dividends)
  • Interest: 15% WHT on interest paid to non-residents (may be reduced under DTTs, often to 5–10%, or 0% for certain financial institutions)
  • Royalties: 15% WHT on royalties paid to non-residents (reduced under DTTs, typically 5–10%)
  • Management fees: 15% WHT on management and technical service fees (reduced under DTTs)
  • Branch profits: 0% (no branch profits tax)

The absence of dividend WHT makes Mauritius one of the best jurisdictions for holding companies, allowing profits to be repatriated to parent companies without further tax leakage.

Double Taxation Treaty Network — Over 45 DTTs

Mauritius has one of the most extensive treaty networks in Africa, with over 45 Double Taxation Treaties (DTTs) in force. Key treaty partners include:

  • India: The Mauritius-India DTT is one of the most utilised treaties for investment into India. Capital gains on shares of Mauritian companies were historically taxable only in Mauritius (0% CGT). Post-2016 Protocol, shares in Indian companies acquired after 1 April 2017 are taxed in India
  • France: Comprehensive treaty with reduced WHT rates on dividends (5%), interest (0%), and royalties (10%)
  • UK: Reduces WHT on dividends to 0%, interest to 5%, and royalties to 10%
  • China: Facilitates Chinese investment into Africa via Mauritius, with reduced WHT rates
  • South Africa: Reduces WHT on dividends to 0%, interest to 0%, and royalties to 5%
  • UAE: Treaty signed but not yet in force (as of 2026)

Most treaties follow the OECD Model Tax Convention and include Limitation of Benefits (LOB) clauses to prevent treaty shopping.

Transfer Pricing Rules

Mauritius has transfer pricing rules aligned with the OECD Transfer Pricing Guidelines and BEPS Actions 8–10. Key requirements:

  • Arm's length principle: All related-party transactions must be at arm's length prices
  • Documentation: Taxpayers must maintain transfer pricing documentation for transactions exceeding specified thresholds
  • Master file and local file: Required for multinational groups with turnover above MUR 1 billion
  • Country-by-Country Reporting (CbCR): Required for groups with consolidated revenue exceeding EUR 750 million
  • Advance Pricing Agreements (APAs): Available for taxpayers seeking certainty on transfer pricing methodologies

Penalties for transfer pricing adjustments include additional tax plus interest. The MRA has a specialised transfer pricing unit.

GBL Regime and Substance Requirements

The Global Business Licence (GBL1) regime offers an effective 3% tax rate on foreign-source income through the 80% deemed Foreign Tax Credit (FDC). However, GBL1 companies must demonstrate economic substance in Mauritius:

  • Physical office: A leased or owned office space in Mauritius
  • Employees: Adequate qualified staff employed in Mauritius (commensurate with the level of activity)
  • Management and control: Board meetings held in Mauritius, strategic decisions made locally
  • Expenditure: Sufficient operating expenditure in Mauritius relative to income
  • Annual filing: Annual audited financial statements and substance declaration (Form 8) filed with the Financial Services Commission (FSC)

Failure to demonstrate substance may result in the company being treated as a domestic company (taxed at 15% without FDC) or subject to penalties.

FAQs

Can a Mauritius company pay dividends to its UK parent without withholding tax?

Yes, under the Mauritius-UK DTT, dividends paid by a Mauritian company to a UK resident company that holds at least 10% of the capital are exempt from Mauritian withholding tax. If the shareholding is below 10%, the rate is 5%.

Does Mauritius have CFC rules?

No, Mauritius does not have Controlled Foreign Company (CFC) rules. This is a significant advantage for holding and investment structures, as passive income earned by a Mauritius company is not attributed to its shareholders.

What is the impact of BEPS on Mauritius's treaty network?

Mauritius has committed to the OECD BEPS Inclusive Framework and has implemented the Multilateral Instrument (MLI) to amend its treaties. Key changes include LOB clauses, principal purpose test (PPT), and mutual agreement procedures. Most recent treaties and renegotiated treaties include these provisions.

Disclaimer

This guide provides general information about Mauritian cross-border taxation for the 2026 tax year. Tax laws and treaties may change. Always consult with a qualified Mauritian international tax advisor or the MRA directly for advice specific to your cross-border structure. InvestmentKit does not provide tax advice.