Global Business Companies (GBC) are taxed at a flat rate of 15% on their chargeable income. However, companies trading in goods are subject to a 3% tax on chargeable income attributed to exports of goods, calculated using a prescribed formula.
“Export of goods” includes the international buying and selling of goods by an entity in its name, whereby the shipment of such goods is made directly by the shipper in the original exporting country without the goods being physically landed in Mauritius.
Partial exemptions
Subject to certain conditions, a company can benefit from a partial exemption on the following sources of income/activities:
- Foreign dividend derived by the company.
- Interest derived by a company other than a bank, non-bank deposit-taking institution, money changer, foreign exchange dealer, insurance company, leasing company and company providing factoring, hire purchase facilities, or credit sales facilities.
- Income derived from ship/aircraft leasing/ locomotives and trains, including rails leasing.
- Income attributable to permanent establishment.
- Income from Collective Investment Scheme (CIS)/Closed-End Fund (CEF)/CIS Manager/CIS Administrator/Investment Adviser/Investment Dealer or Asset Manager approved by the Financial Services Commission (FSC).
- Reinsurance/Reinsurance brokering activities.
- Leasing & provision of international fibre capacity.
- Sale, financing, arrangement, asset management of aircraft and its spare parts and aviation advisory services related thereto.
- Interest derived by a person from money lent through a peer-to-peer lending platform.
- Income derived by a company holding a Robotic and Artificial Intelligence Enabled Advisory Services licensed or approved by the FSC.
- Income derived by a company holding a Payment Intermediary Services licensed or approved by the FSC.
Note: 95% partial tax exemption is applicable on interest derived by a CIS or a CEF licensed or approved by the FSC.
Criteria and conditions to meet for the use of partial exemption by a company
For companies other than pure equity holdings, the following conditions must be met:
- It must carry out its core income-generating activities in Mauritius.
- It must employ, directly or indirectly, an adequate number of suitably qualified persons to conduct its core income-generating activities.
- It must incur a minimum expenditure proportionate to its level of activities.
- For pure equity holding companies, the following conditions must be met.
- Comply with all applicable corporate law filing requirements
- Have adequate human resources and adequate premises in the country for holding and managing equity participation in other entities.
Note that under domestic law, a company is allowed to claim the actual foreign tax suffered as a credit against its Mauritian tax liability. However, the tax credit cannot exceed the Mauritian tax payable, and any excess is not refundable and cannot be carried forward to the next year. Also, a Company can either claim a partial exemption or foreign tax credit on a source of income.
Withholding tax (WHT)
There is no withholding tax in Mauritius for payments made by GBCs to non-residents not carrying out any business in Mauritius out of their foreign-source income. There is no WHT on dividends received from resident companies and on payments made by a company having an annual turnover of less than MUR 6 million.
The rate of TDS may be reduced under any applicable double taxation agreement between Mauritius and the jurisdiction of the recipient. Currently Mauritius has DTA with 46 countries (22 July 2024).
VAT (Value added tax)
A GBC is not required to be VAT-registered if all its activities are outside Mauritius. However, if a GBC has taxable supplies in Mauritius (standard and zero rated) and its total taxable supplies exceed the threshold of Rs6M annually, VAT registration is mandatory.
CCR levy
Corporate Climate Responsibility (CCR) Levy is applicable to companies, with year of assessment starting 1 July 2024 and with turnover exceeding MUR 50 million. Turnover is defined as gross income, including exempt income, derived from all sources. The CCR levy is calculated at 2% of the chargeable income of the current income year. The purpose of this new tax is to fund climate change initiatives.
