Mauritius Taxation
The corporate income tax rate in Mauritius is 15%, there are no capital gains tax, no inheritance tax, no withholding tax on dividends and interests.
And from budget 2012 in order to boost investment and growth:
- Abolition of solidarity tax on dividends and interest
- Abolition of Capital gains tax on immovable property
- Abolition of business rates by municipalities
- Corporate social responsibility tax to be computed on chargeable income
- Tax on gains from sale or transfer of immovable property is abolished unless in the normal course of business
- Tax holiday of Freeport operators will be carried forward indefinitely
- Indefinite income tax exemption for companies operating in the Freeport Zone as an incentive to reinforce and enhance freeport and logistics platform
- A Protected Cell Company (PCC) to pay tax on the chargeable income of each cell
- Companies in the Global Business sector allowed to pay income tax in any approved convertible foreign currency
- Exemption of Advance Payment System submissions for companies with an annual turnover not exceeding Rs2m
- The “double deduction” for foreign marketing and promotional expenses granted to companies engaged in tourism and export activities will be abolished as from Jan 2012
- SMEs will be provided with an annual grant not exceeding rs100K to finance their participation in international fairs
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Double Taxation Avoidance Treaties Network
| Year |
Country |
Dividends |
Interest |
Royalties |
Capital
Gains |
DTA Download |
| Signed |
Ratified |
Substantial
interest |
Portfolio |
Banks |
Others |
| 2004 |
2005 |
Barbados |
5% |
5% |
5% |
5% |
5% |
(d) |
 |
| 1995 |
1999 |
Belgium |
5%(b) |
10% |
Exempt |
10% |
Nil |
(d) |
|
| 1995 |
1996 |
Botswana |
5%(a) |
10% |
12% |
12% |
12.50% |
(d) |
|
| 1994 |
1995 |
China |
5% ** |
5% ** |
10% |
10% |
10% |
(d) |
|
| 2002 |
2003 |
Croatia |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
0% |
|
| 2000 |
2000 |
Cyprus |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
(d) |
|
| 1980 |
1982 |
France |
5%(b) |
15% |
Exempt |
(c) |
15% |
(d) |
|
| 1978 |
1981 |
Germany |
5%(a) |
15% |
Exempt |
(c) |
15% |
(d) |
|
| 1982 |
1985 |
India |
5%(b) ** |
15% ** |
Exempt |
(c) |
15% |
(d) |
|
| 1990 |
1995 |
Italy |
5%(a) |
15% |
(c) |
(c) |
15% |
(d) |
|
| 1997 |
1998 |
Kuwait |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
10% |
(d) |
|
| 1997 |
2004 |
Lesotho |
10% |
10% |
10% |
10% |
10% |
(d) |
|
| 1995 |
1996 |
Luxembourg |
5%(b) |
10% |
(e) |
(e) |
(e) |
(d) |
|
| 1994 |
1995 |
Madagascar |
5%*** |
10% |
10% |
10% |
5% |
(d) |
|
| 1992 |
1993 |
Malaysia |
5%(b) |
15% |
15% |
15% |
15% |
(d) |
|
| 1997 |
1999 |
Mozambique |
8%(a) |
10% |
Exempt |
8% |
5% |
(d) |
|
| 1995 |
1996 |
Namibia |
5%(a) |
10% |
Exempt |
5% |
5% |
(d) |
|
| 1999 |
1999 |
Nepal |
5% (h) |
15% |
10% (i) |
15% |
15% |
(d) |
|
| 10% (b) |
| 1998 |
1998 |
Oman |
0% (e) |
0% (e) |
0% (e) |
0% (e) |
0% (e) |
(d) |
|
| 1994 |
1995 |
Pakistan |
10% |
10% |
10% |
10% |
12.50% |
(d)* |
|
| 2001 |
2003 |
Rwanda |
Exempt |
Exempt |
Exempt |
Exempt |
Exempt |
(d) |
|
| 2002 |
2003 |
Senegal |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
(d) |
|
| 2005 |
2005 |
Seychelles |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
(d) |
|
| 1995 |
1996 |
Singapore |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
(d) |
|
| 1996 |
1997 |
South Africa |
5%(b) ** |
15% ** |
Exempt |
Nil |
Nil |
(d) |
|
| 1996 |
1997 |
Sri Lanka |
10%(b) |
15% |
Exempt (g) |
10% |
10% |
(d) |
|
| 1994 |
1994 |
Swaziland |
7.50% |
7.50% |
5% |
5% |
7.50% |
(d) |
|
| 1992 |
1992 |
Sweden |
5%(b) |
15% |
Exempt |
15% |
15% |
(d) |
|
| 1997 |
1998 |
Thailand |
10% |
10% |
10% |
15% |
5%-15% |
(d) |
|
| 2008 |
2008 |
Tunisia |
Exempt |
Exempt |
2.5% |
2.5% |
2.5% |
(d) |
|
| 2003 |
2004 |
Uganda |
10% |
10% |
10% |
10% |
10% |
(d) |
|
| 1981 |
1987 |
U.K. (and Northern Ireland) |
15% |
15% |
Exempt |
(c) |
15% |
(d) |
|
| 2006 |
2007 |
United Arab Emirates |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
Exempt (e) |
(d) |
|
| 1992 |
1992 |
Zimbabwe |
10%(a) |
20% |
Exempt |
10% |
15% |
(d) |
|
|
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- Shareholding at least 25%.
- Shareholding at least 10%.
- Interest taxed in source country in accordance with taxation laws of that country.
- Generally taxable in the alienator’s country of residence, except for the alienation of immovable property and immovable property forming part of the business property of a Permanent Establishment.
Gains from alienation of ships or aircraft taxable in the state in which the place of effective management of the enterprise is situated.
- Dividends / Interests / Royalties are taxable only in the recipient’s country of residence.
- Shareholding at least 20%.
- If the loan is from state-owned bank or institution.
- Shareholding at least 15%
- Exempt if Government owned/controlled financial institution, otherwise 10%.
- Not taxable in the contracting states
- Exempt if Government owned/controlled financial institution & the central bank otherwise 2.5%.
- Treaty is being revised
|
| * |
Arising on the sale of shares and other securities in Pakistan. Listed shares on the Stock Exchange are exempt up to the year ending 30 June 2010. |
| ** |
The maximum rates of withholding tax on dividends applicable in accordance with the DTA. Currently there is no withholding tax on dividends in accordance with the laws of that state. |
| *** |
Company qualified under the “Code des Investissements” or capital risk company. |
|
3 treaties await ratification: Congo, Russia, Vietnam and Zambia.
5 treaties await signature: Egypt, Malawi, Kenya, Nigeria and Ghana
12 treaties are being negotiated with: Canada, Czech Republic, Egypt, Greece, Monaco, Portugal, Republic of Iran, Burkina Faso, Algeria, St Kitts and Nevis, Yemen, Vietnam and Saudi Arabia. |
| |
| Tax Information Exchange Agreements (TIEAs) |
1 TIEA awaits ratification :Australia
6 TIEAs await signature: Denmark, Finland, Faroe Island, Greeland, Iceland and Norway |
| |
| Tax Residence Certificate (TRC) |
| For a GBL Category 1 company to be tax resident in Mauritius and to gain access to the benefits of the DTA network, a TRC issued by the MRA under the recommendation of the FSC in Mauritius is required. The application process can take up to 15 days depending on the complexity of the structure. The company must show that it is centrally managed and controlled in Mauritius, and the following minimum requirements can satisfy this condition: |
- Two directors resident in Mauritius;
- Maintain its registered office and all statutory records in Mauritius.
- Board meetings held in Mauritius. Telephonic participation is permitted provided the meeting is initiated and chaired in Mauritius;
- Maintain an account with a local bank through which funds must flow.
- A local qualified company secretary; and
- A local auditor.
|
Investors should ensure that the relevant conditions are also satisfied in the country of investment to guarantee eligibility of treaty benefits.
Tri-Pro can provide TRC application with MRA through FSC and will ensure that all companies adhere to the above conditions and thus qualify for tax residency in Mauritius.
|
| Investment Promotion and Protection Agreements (IPPAs) |
| Mauritius has signed IPPAs with 30 countries, one of which (South Africa) is already in force (Source: Ministry of Foreign Affairs - Mauritius). |
The IPPAs normally guarantees the following to the investors from the contracting states:
- free repatriation of investment capital and returns;
- guarantee against expropriation;
- most favoured nation rule with respect to treatment of investment, compensation for losses in case of war or armed conflict or riot; and
- arrangement for settlement of disputes between investors and the contracting states.
|
| |
Country |
Date of Signature |
|
Country |
Date of Signature |
| 1 |
Germany |
25-May-71 |
17 |
Zimbabwe |
17-May-00 |
| 2 |
France |
22-Mar-73 |
18 |
Benin |
18-May-01 |
| 3 |
United Kingdom |
20-May-86 |
19 |
Burundi |
18-May-01 |
| 4 |
China |
04-May-96 |
20 |
Ghana |
18-May-01 |
| 5 |
Mozambique |
14-Feb-97 |
21 |
Mauritania |
18-May-01 |
| 6 |
Indonesia |
05-Mar-97 |
22 |
Tchad |
18-May-01 |
| 7 |
Pakistan |
03-Apr-97 |
23 |
Comoros |
18-May-01 |
| 8 |
Portugal |
12-Dec-97 |
24 |
Guinea Republic |
18-May-01 |
| 9 |
South Africa |
17-Feb-98 |
25 |
Rwanda |
30-Jul-01 |
| 10 |
India |
04-Sep-98 |
26 |
Cameroon |
03-Aug-01 |
| 11 |
Switzerland |
26-Nov-98 |
27 |
Senegal |
14-Mar-02 |
| 12 |
Czech Republic |
05-Apr-99 |
28 |
Sweden |
23-Feb-04 |
| 13 |
Nepal |
03-Aug-99 |
29 |
Madagascar |
06-Apr-04 |
| 14 |
Romania |
20-Jan-00 |
30 |
Barbados |
28-Sep-04 |
| 15 |
Singapore |
04-Mar-00 |
31 |
Botswana |
15-Aug-05 |
| 16 |
Swaziland |
15-May-00 |
|
|
|
|
| IPPAs awaiting signature: Chile, Korea, Malawi, Turkey, and Uganda. |
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