Treaty access depends on substance
Corporate Tax Registration & Returns in Mauritius
Mauritius tax outcomes depend on substance. Without it, the treaty network is not available to you.
GCC business setup specialists
The exemption is conditional
Mauritius applies a headline corporate rate with a partial exemption regime for certain foreign-source income. Access to both that regime and the treaty network depends on meeting substance conditions, which are tested rather than assumed.
- Substance conditions explained before you rely on them
- Partial exemption position assessed honestly
- Treaty access addressed with realism, not optimism
20+
Mainland, free zone and offshore jurisdictions we file in — so the recommendation is based on your activity, not on which authority we happen to be registered with.
7,000+
Companies successfully established.
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What applies
Mauritius tax obligations
Which apply depends on your regime and your substance.
| Item | Who it affects | What we do |
|---|---|---|
| Corporate tax return | Resident companies | Prepare and file with the MRA |
| Partial exemption | Qualifying foreign-source income | Assess eligibility against substance conditions |
| Substance conditions | Companies claiming exemption or treaty benefits | Set out what is required and document it |
| Treaty access | Global Business Companies with substance | Assess realistically; obtain residence certification where appropriate |
| Authorised Company | Non-resident treatment | File as required; no treaty access |
| Capital gains | Generally not taxed in Mauritius | Confirm the position for your assets |
Rates, the partial exemption regime, substance conditions and treaty positions are set by the Mauritian authorities and change, and are subject to international scrutiny. Your position is confirmed in writing before filing.
How it works
From registration to filed return
Substance is established before benefits are claimed.
01
Assess the position
Your regime, whether partial exemption is genuinely available, and what substance would be needed to support it.
02
Register and build the record
Tax registration completed and the substance evidence maintained as you go rather than assembled retrospectively.
03
File and support
Return prepared from audited statements, explained before filing, and the basis documented.
To assess your position
What we need to look at
Substance rests on facts, not intentions.
- Certificate of incorporation and licence
- Audited financial statements
- Where directors are resident
- Where board meetings are held
- Local employment and expenditure
- Where the principal bank account is
- Income types and their sources
- Counterparty jurisdictions
- Whether treaty benefits will be claimed
- Group structure chart
- Prior tax returns and assessments
- Any MRA correspondence
Scope
What is included, and what is not
Stated plainly, so nothing is added once the engagement starts.
Included in the service fee
- Assessment of your tax position
- Substance conditions set out in writing
- Tax registration
- Corporate tax return preparation and filing
- Partial exemption position documented
- Guidance on residence certification where appropriate
- Deadline tracking
- A named adviser who explains the position
Not included, quoted separately
- MRA fees and taxes payable
- Penalties arising before our engagement
- The statutory audit itself
- Formal tax opinions on treaty positions
- Tax residence certificate applications, quoted separately
- Transfer pricing studies
- Representation in an MRA audit
- Tax advice in other jurisdictions
Verify independently
Official Mauritian authorities
We file directly with these bodies on your behalf.
Corporate and Business Registration DepartmentFinancial Services CommissionMauritius Revenue AuthorityEconomic Development BoardRegistrar of CompaniesIndustrial Property Office
Questions
Mauritius corporate tax — FAQs
What is the partial exemption regime?
A regime exempting a portion of certain foreign-source income, available where substance conditions are met. It replaced earlier arrangements and is conditional, not automatic.
Can I access Mauritius tax treaties?
A Global Business Company with genuine substance may. An Authorised Company cannot, because it is treated as non-resident. Treaty access is also scrutinised in the counterparty country.
What does substance actually require?
Broadly, management and control in Mauritius: resident directors, board meetings held here, a local principal bank account, and core income-generating activities carried out here with appropriate employment and expenditure.
Is there capital gains tax?
Mauritius does not generally tax capital gains, though the treatment of specific assets should be confirmed.
Will a treaty claim be accepted?
That depends on both Mauritius and the counterparty country, and claims are increasingly tested. We will tell you when a claim looks weak rather than encouraging it.
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