Mauritius corporate tax: rates, substance and the full cost

The company’s residence follows legal and factual tests

Section 73 makes incorporation in Mauritius or central management and control in Mauritius a corporate residence connection. Section 73 A then treats a Mauritius-incorporated company as nonresident where its central management and control is outside Mauritius, while preserving its return requirement. A foreign company can also acquire a Mauritius residence connection through actual management here.

Document who sets strategy, approves significant contracts, controls financing and accepts risk. A local director’s signature does not establish independent authority if decisions are made elsewhere. The owner’s previous country may still assert company residence, a permanent establishment, transfer-pricing adjustments or CFC attribution. Those are separate questions from Mauritian incorporation.

15% is a starting rate, not a complete structure quote

The ordinary corporate income-tax rate is 15%. The 3% regime concerns qualifying exports of goods, including defined merchanting where goods ship directly between other countries; it is not a general rate for overseas consultancy clients. Finance Act 2026 revises the export definition, including aviation fuel and excluding live animals.

Partial exemption can reduce qualifying income, but the income category, licence, employees, expenditure and core income-generating activity conditions must be tested. An 80% exemption from a 15% rate is an arithmetic 3% on the relevant income before other applicable charges. It is not evidence that the whole company, every receipt or every distribution bears 3%.

Foreign tax credits and partial exemption require a consistent computation. Map each revenue stream, deductibility, source, exemption and credit before forecasting the effective rate. The FSC’s July 2026 survey specifically examines partial-exemption claims and distinguishes pure-equity holding from other investment activity.

The additional corporate charges to model

Corporate fair-share contribution is separate from personal FSC. Finance Act 2026 section 25(o) replaces VAT Act section 53 N(1): a company with chargeable income above MUR 24m falls into the chargeability gateway, without the earlier VAT-registration/turnover limb. Published contribution rates are 2% for a company taxed at 3% and 5% for a company taxed at 15%; banks have a separate calculation. The temporary corporate regime runs to 30 June 2028 under its governing provisions.

The corporate climate-responsibility levy is 2% of chargeable income where the relevant annual turnover exceeds MUR 50m. Finance Act 2026 changes instalment collection and introduces phased reductions to specified advance instalments, followed by annual reconciliation. That cash-flow mechanism should not be described as permanently reducing the underlying 2% liability.

CSR generally uses 2% of the previous year’s chargeable income, with statutory exclusions and special treatment for categories including global business. The proportion remitted to MRA is not the same as the total CSR fund: the 2026 Act provides at least 50% for funds established during 2026, reverting to at least 75% from 2027. Check the company category before adding CSR mechanically.

Groups meeting the EUR 750m consolidated-revenue threshold in at least two of the preceding four fiscal years must consider the domestic minimum top-up framework. The 15% Glo BE effective-rate test and exclusions are not the same computation as ordinary 15% company tax. Smaller standalone businesses should not be shown a Pillar Two charge by default.

Controlled foreign companies: control is only the first question

Section 90 A concerns a resident company carrying on business through a controlled foreign company, including a foreign permanent establishment. More than 50% of participation rights must be held directly or indirectly by the resident company, alone or with associated enterprises. The rule targets undistributed income arising from non-genuine arrangements put in place essentially to obtain a tax benefit.

The significant-people-functions test asks whether the foreign entity would own the assets or undertake the risks without the Mauritian company’s controlling functions. There are alternative exclusions, including profits no more than EUR 750,000 with non-trading income no more than EUR 75,000; profits below 10% of defined operating costs; or the foreign tax rate above 50% of the Mauritius rate. The operating-cost definition excludes specified outside-country goods and associated-party payments.

This identified CFC provision is corporate. It should not be displayed as an identical direct attribution rule for every individual shareholder. The shareholder’s other country of residence may nevertheless apply its own personal CFC rules.

Substance, licensing and foreign management

A global business licence, an ordinary domestic company and an authorised-company arrangement are different regulatory/tax choices. The appropriate activity and licence must be established before banking or advertising financial services. Applications for regulated activities go through the FSC; a company certificate alone is insufficient.

Where a strategy requires Mauritius management, design genuine decision rights, capable personnel, records, premises and expenditure for the actual business. The FSC monitors core income-generating activities and tax preferences. Offshore Capitalist can assess the need and introduce independent management providers; we do not supply foreign management and control internally.

Intercompany contracts should follow the functions, assets and risks that exist in practice. Section 75 permits arm’s-length adjustment. A contract allocating all profit offshore will not fix staff, sales, decision-making or delivery that remain in another country.

VAT and payment withholding need their own workstream

The standard VAT rate is 15%. The general registration threshold was reduced from MUR 6m to MUR 3m under the 2025 reform, and specified activities can require registration irrespective of turnover. Zero-rated supplies, exempt supplies and supplies outside scope are different: they do not all produce the same input-tax recovery.

Finance Act 2026 revises the foreign-digital-services registration provisions from 1 October 2026, including a threshold and an exception where services are supplied exclusively to VAT-registered persons. Cross-border software and platform businesses should determine supplier status, place of supply and customer VAT status rather than apply the domestic small-business test automatically.

The same Act adds 1% tax deduction at source for qualifying ICT-service payments above MUR 300,000 and 5% for specified digital advertising, promotional, endorsement and marketing payments by non-individual payers. Treaty limits can matter for nonresident recipients. Withholding is not automatically the final tax, and the payer’s obligation needs separate implementation.

People, payroll and keeping the company operable

Budget salary, statutory year-end bonus, payroll withholding, CSG, NSF and the training levy separately. A professional occupation permit is tied to qualifying employment, while the self-employed route is narrowly framed around the applicant’s own services business. Do not select a cheap immigration category and then run a different operating model.

For workers within the relevant statutory scope, normal weekly hours are 45 excluding meal and tea breaks; overtime and public-holiday work have separate rates. Section 54 provides an annual bonus of one-twelfth of earnings for qualifying workers, using a monthly basic-wage ceiling of MUR 100,000 for that section. Continuous employment and the timing of departure affect entitlement. Leave, retirement-gratuity, sectoral orders and contractual benefits require their own coverage review.

The implementation file should identify the accountant, payroll calendar, beneficial-owner records, banking mandates, licence renewals and evidence of actual decisions. Before a later relocation, review whether management moves with the founder, whether assets or contracts transfer, and which countries retain taxing rights. This research has not established a universal no-exit-tax rule for every company transaction.