Departure does not erase the income-year tests
Leaving on a flight is a fact, not a complete tax-residence conclusion. Recalculate all section 73 tests for the July–June income year, including the 270-day aggregate with the two preceding years and any domicile/permanent-abode issue. Document your new home and intended duration abroad alongside the travel record.
If two countries claim residence, determine the relevant treaty position. Income sourced in Mauritius can remain taxable after personal nonresidence, and resident-company obligations do not disappear because its shareholder moves.
Close or change the permission deliberately
A professional permit follows the employment basis: the employer must notify the relevant authorities when it ends, and a fresh application is required for a new employer. Other routes require review when the business stops, transfer conditions fail or the sponsor leaves. Dependents’ permissions are linked to the main holder.
For property-linked residence, a disposal can end the residence basis. The IRS/RES/PDS guidelines require advance notice to EDB before a sale or transfer. Have the notary and immigration adviser coordinate the deed, applicable duties and the household’s next permission rather than assume the card survives sale.
The company needs its own departure analysis
If the founder has exercised strategic control from Mauritius, moving them may change where the company is managed. Review board powers, executive work, financing, contract approval, staff and fixed places of business in both countries. Corporate residence, permanent establishment, licensing and the bank’s understanding of operations should stay consistent.
Contracts, assets, trading stock, intellectual property and employees cannot simply be relabelled as belonging to another country. Section 75’s arm’s-length standard and the ordinary tax rules remain relevant to restructuring. A general personal mark-to-market exit charge was not established in this research; that is not a conclusion that every business transfer or departure is tax-free.
Returns and account access after departure
Reconcile payroll, business income, remittances, foreign credits and any amounts withheld before deciding which final or continuing returns are required. Preserve electronic access and an authorised local contact if correspondence or an assessment arrives later. Tell banks about the address, residence and beneficial-owner changes they require.
Retain acquisition records and pre-arrival capital evidence for the next country. The new country’s investment basis may be historical cost, a conditional adjustment or market value; Mauritius’s treatment does not determine it. Any pension, property, company or bank account retained here should appear in the next-country reporting review.
If citizenship has been acquired
Registered or naturalised citizens should review the retention rules before a lengthy overseas move. Section 11(4) addresses five continuous years ordinarily resident abroad and specified ways of preserving the documented connection or intention to retain citizenship. Section 12 also raises route-specific foreign-rights issues. Citizenship should not be treated as an administrative card that can safely be ignored after relocation.
The 2026 Act repeals section 11(8)’s exceptional no-reasons deprivation power. That change does not repeal all the remaining loss and retention provisions. We can arrange a coordinated exit review so immigration, company and tax advice address the same facts.
Sources & research notes8 references
Sources supporting this guide. Research draft awaiting editorial review.
- Income Tax Act 1995 — MRA consolidation through May 2026
- EDB — Occupation and retired residence permit guidelines, current download
- EDB — IRS, RES and PDS buyer guidelines
- FSC — monitoring substance, 2 July 2026
- MRA — individual return notes, assessment year 2026/27
- SBM — individual account opening form, May 2026
- Mauritius Citizenship Act — official consolidated text
- Economic and Financial Measures Act 2026, Act 13