OECD Pillar Two in Mauritius.

For global information on OECD Pillar Two and the global minimum tax for multinational groups in all markets, seeAcclime Group’s guide.

Mauritius has enacted a Qualified Domestic Minimum Top-up Tax (QDMTT), aligning with the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) Rules and introducing a 15% minimum effective tax rate for large multinational enterprise (MNE) groups operating in or through Mauritius. The GloBE rules were first referenced in the Finance Act 2022, with the detailed QDMTT provisions introduced by the Finance Act 2025, effective for the year of assessment commencing 1 July 2025.

Like a number of other jurisdictions, Mauritius has adopted only the QDMTT. It has not introduced the Income Inclusion Rule (IIR) or the Undertaxed Profits Rule (UTPR), and detailed implementing guidance from the Mauritius Revenue Authority (MRA) is still awaited on several points. This guide focuses on Mauritius’s implementation, filing obligations and local considerations.

At a glance

Local summary

Mauritius collects top-up tax on low-taxed Mauritius profits through the QDMTT, ensuring a minimum effective tax rate (ETR) of 15% for in-scope groups. Where the combined ETR of an MNE group’s Mauritius members falls below 15% in a fiscal year, a top-up tax is due locally to bring the Mauritius ETR up to 15%. By collecting this domestically, Mauritius retains revenue that would otherwise be collected by the parent’s jurisdiction under an IIR or UTPR. The QDMTT applies for the year of assessment commencing 1 July 2025, to Mauritius members of in-scope groups whose ultimate parent entity has a fiscal year ending on or after 1 January 2025.

Scope and key concepts

The QDMTT applies to MNE groups meeting the EUR 750 million consolidated revenue threshold. In Mauritius, it applies to resident companies that are members of an in-scope group, and to an ultimate parent entity incorporated in Mauritius, where the global group meets the threshold. Certain entities are excluded, including investment funds, pension funds, real estate investment vehicles and insurance investment entities, and international shipping income is outside the scope of the top-up calculation.

Because Mauritius applies only a QDMTT, the top-up tax on low-taxed Mauritius profits is collected domestically rather than by a foreign parent under an IIR or UTPR. GloBE income for the QDMTT follows the default GloBE rules, based on each entity’s financial accounting net income before the consolidation adjustments made in the ultimate parent entity’s consolidated financial statements. The Act does not provide for the use of a local accounting standard.

Local deviations

Mauritius’s rules are broadly aligned with the OECD GloBE Model Rules. Its principal feature is structural: it has implemented only a domestic minimum top-up tax, and has not adopted the IIR or UTPR. A number of detailed parameters are still to be prescribed by regulation, including the substance-based income exclusion percentages and definitions, the treatment of safe harbours, and how the QDMTT will interact with the partial exemption regime.

Compliance and filing obligations

In-scope groups with a Mauritius constituent entity have a notification obligation and a return-and-payment obligation with the MRA. A designated Mauritius-resident company may be appointed to file the return and pay the tax for the group’s Mauritius members. If no designated person is appointed, each constituent entity files its own return.

Key deadlines

The compliance obligations

Notification

Each in-scope Mauritius resident company notifies the MRA no later than six months from the end of the MNE group’s fiscal year, of the designated Mauritius-resident person responsible for filing the QDMT tax return and paying the tax due. When the regime first took effect, the MRA issued communiqués extending certain notification deadlines that were already due, so groups should check the MRA’s current guidance for any transitional administrative dates.

QDMT tax return and payment

The designated person files the QDMT tax return and pays the tax due not later than 15 months from the end of the fiscal year. Unlike the OECD model and many other jurisdictions, the Mauritius rules do not provide an extended 18-month deadline for the first year, so the 15-month deadline applies from the outset. If no designated person is appointed, each constituent entity filesf its own return.

Safe harbours and pending guidance

At the date of this guide, the MRA has not yet issued detailed QDMTT implementing guidance, and the safe harbour position is not yet known. It is not yet confirmed whether Mauritius will adopt the OECD transitional CbCR safe harbour, the mechanics of which are explained in Acclime’s Group guide. The substance-based income exclusion percentages and definitions, and the interaction with the partial exemption regime, are also still to be prescribed. In-scope groups should monitor MRA guidance closely.

Tax incentive impact

Mauritius operates a partial exemption regime, under which a portion of certain income streams such as foreign-source dividends and interest is exempt, along with tax holidays and a reduced 3% rate for the export of goods. For in-scope groups, these can reduce the Mauritius effective tax rate below 15%, in which case the shortfall may be recovered through the QDMTT, or under another jurisdiction’s Pillar Two rules where applicable. The substance-based income exclusion provides a carve-out for qualifying payroll and tangible assets in Mauritius, but the applicable percentages and definitions are still to be prescribed by regulation.

Monitoring, audit and disputes

The MRA administers the QDMTT, including the notification, the QDMT tax return and payment. Because several detailed parameters remain to be prescribed, in-scope groups should monitor MRA guidance, model their potential exposure, and keep supporting records and calculations under review. Groups may use the usual Mauritius tax objection and dispute mechanisms in relation to assessments or collection actions.

Key local issues

The penalties for late payment and the still-developing nature of the detailed rules are the main points to note.

Beyond penalties, the principal practical issue is that several detailed rules are not yet finalised, including the safe harbour position, the substance-based income exclusion parameters, and the interaction with the partial exemption regime. Until the MRA issues further guidance, in-scope groups should treat their Mauritius position as provisional and revisit it as the rules are clarified.

Local contact

For advice on how Pillar Two applies to your group’s Mauritius operations, please contact Acclime Mauritius about their tax services regarding OECD Pillar Two.