Double Taxation Avoidance Treaties

Mauritius has, as a tax planning jurisdiction focused the development of its Global Business sector on the use of its growing network of Double Taxation Avoidance Treaties (DTAs). The expanding network of these DTAs reinforces the seriousness of Mauritius as a tax efficient jurisdiction for structuring investment abroad in the Global Business sector. Mauritius has been used as a route for investment into emerging regions such as India and China.

Entities holding a Category 1 Global Business Licence wishing to avail to the benefits of a tax treaty must obtain a Tax Residence Certificate issued by the Commissioner of Income Tax in Mauritius.

 

Further information is available on the web pages of the Mauritius Revenue Authority.

 

So far, Mauritius has concluded 33 tax treaties and is party to a series of treaties under negotiation.

 

The treaties currently in force are as follows:

 

Countries

1.

Barbados

17.

Namibia

2.

Belgium

18.

Nepal

3.

Botswana

19.

Oman

4.

China

20.

Pakistan

5.

Croatia

21.

Rwanda

6.

Cyprus

22.

Senegal

7.

France

23.

Seychelles

8.

Germany

24.

Singapore

9.

India

25.

South Africa

10.

Italy

26.

Sri Lanka

11.

Kuwait

27.

Swaziland

12.

Lesotho

28.

Sweden

13.

Luxembourg

29.

Thailand

14.

Madagascar

30.

Uganda

15.

Malaysia

31.

United Arab Emirates

16.

Mozambique

32.

United Kingdom

 

 

33.

Zimbabwe

 

 


Fiscal Regime

 

 

 

Fiscal Regime applicable to Companies holding a Category 1 and 2 Global

Business Licenses:

As from 1st July 1998, a company with a Category 1 Global Business Licence is liable to a uniform tax rate of 15% as provided for under the Income Tax Act 1995. Such a change is aimed at facilitating the extension of the Mauritius tax treaty network as well as creating a level playing field for the domestic and the global business sector (previously known as the offshore sector). Pursuant to the Finance Act 1998, a company with a Category 1 Global Business Licence was able to elect, by notice in writing given simultaneously to the Commission and to the Commissioner of Income Tax, to pay Income Tax at a rate exceeding 15% ; the rate of tax on the Company is chargeable income being specified in the notice.  However, after the Finance Act 2000, companies incorporated after 1st July 1998 are subject to a uniform rate of 15%.

 

Companies incorporated prior to 1st July 1998, which before the Finance Act 2000 were able to choose to be taxed between 0% to 35%, could elect to be irrevocably governed by the Income Tax Act 1995 and taxed accordingly.  These companies shall make such election by 30 June 2002, failing which, the companies will be taxed at 15% on its income derived as from 1st July 2002.

 

A Company with a Category 2 Business Licence is tax exempt and it cannot avail of double taxation relief under the tax treaties in force in Mauritius.

 

A resident Société with a Category 1 Global Business Licence is not liable to income tax. However, every associate of the société is liable to income tax in respect of his share of income in that société. The associate has the option of being taxed as an individual at a maximum rate of 15%, or as a company at the tax incentive rate of 15%.

  

 

Other Fiscal Incentives

  •  No withholding taxes on dividends paid out of income from approved global business  activities
  •  No withholding tax on interest
  • No capital gains tax
  • No estate duty or inheritance tax payable on the inheritance of shares in a global business entity
  • A concessionary personal income tax rate for expatriate employee or of a specified Mauritian employee of a company holding a Category 1 Global Business Licence 

 

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