Mauritius has developed into a recognised international financial centre connecting Africa, Asia and the rest of the world. For investors considering where to establish a holding company, investment vehicle, international business or family wealth structure, the jurisdiction combines a competitive tax framework with an established regulatory system, a broad treaty network and access to professional financial services.
The advantages, however, go beyond headline tax rates. Increasingly, international investors must demonstrate genuine commercial purpose, appropriate economic substance and sound governance. Understanding how the Mauritian framework works in practice is therefore essential before choosing a structure.
Why International Investors Look at Mauritius
Mauritius is not a zero-tax jurisdiction. Its international financial centre is based on a moderate-tax system supported by Double Taxation Avoidance Agreements, domestic tax incentives for qualifying activities and a regulated Global Business regime.
Mauritius currently has a network of 45 tax treaties. Depending on the relevant treaty and the nature of an investment, these agreements may reduce withholding taxes, allocate taxing rights between jurisdictions and provide mechanisms to relieve double taxation.
Mauritius also operates a hybrid legal system influenced by both French civil law and English common law principles. Corporate and commercial legislation is largely based on common-law concepts, while the Judicial Committee of the Privy Council remains the final court of appeal.
The jurisdiction is also subject to international standards relating to tax transparency, anti-money laundering and counter-terrorist financing. For international structures, compliance, beneficial ownership transparency and economic substance are consequently central considerations.
Corporate Tax in Mauritius
The general corporate income tax rate in Mauritius is 15%.
A reduced rate of 3% applies to profits attributable to qualifying exports of goods, subject to the provisions of the Income Tax Act.
Mauritius also operates a partial exemption regime under which specified categories of income may qualify for an 80% or, in certain cases, 95% exemption.
Qualifying categories include, subject to the applicable statutory conditions, certain foreign dividends, interest income and income derived from specified financial services and fund-related activities.
Where an 80% partial exemption applies to income otherwise taxable at 15%, the resulting effective tax rate on that qualifying income is 3%.
The exemption should not, however, be viewed as an automatic 3% corporate tax regime. Eligibility depends on the nature of the income and compliance with the conditions prescribed under Mauritian tax legislation, including applicable substance requirements.
Corporate Climate Responsibility and Fair Share Contributions
Companies should also consider levies that may apply in addition to ordinary corporate income tax.
The Corporate Climate Responsibility Levy is generally imposed at 2% of chargeable income where the company’s turnover exceeds MUR 50 million, subject to statutory exemptions and conditions.
A separate Fair Share Contribution applies to qualifying companies for the period prescribed under the relevant legislation. Its applicability and rate depend on factors including chargeable income and the company’s underlying tax rate.
These additional charges mean that headline corporate income tax rates should never be considered in isolation when modelling the overall tax cost of a Mauritius structure.
Capital Gains
Mauritius does not impose a standalone capital gains tax.
Capital gains are therefore generally outside the scope of income tax. However, the distinction between a capital gain and taxable business or trading income depends on the relevant facts and circumstances.
An investor disposing of shares or other assets through a Mauritius company must also consider the tax rules of the jurisdiction in which the underlying investment is situated and any applicable Double Taxation Avoidance Agreement.
Accordingly, the absence of a Mauritian capital gains tax does not necessarily mean that a transaction will be free from tax in every jurisdiction concerned.
No Inheritance Estate or Gift Tax
Mauritius does not generally impose inheritance tax, estate duty or gift tax. This can make the jurisdiction attractive for succession planning and long-term family wealth structures, including trusts, foundations and family holding companies.
However, the absence of inheritance or estate taxation in Mauritius does not necessarily mean that a transfer will be tax-free in every case. The tax residence of the deceased, donor or beneficiaries, as well as the location of the underlying assets, may give rise to tax consequences in other jurisdictions.
Succession planning must also take account of Mauritian civil law principles, including forced-heirship rules that may reserve certain rights for heirs. Trusts, foundations and other wealth-planning structures may assist in addressing succession objectives, but their effectiveness depends on the circumstances of the family, the location of the assets and the laws of the jurisdictions concerned.
Dividends and Repatriation of Profits
Dividends paid by a company resident in Mauritius are generally exempt from Mauritian income tax in the hands of the recipient under the applicable domestic provisions.
Mauritius also generally does not impose withholding tax on ordinary dividend distributions.
This can facilitate the repatriation of profits from Mauritius structures, although the tax treatment in the shareholder’s country of residence must always be considered separately.
Personal Income Tax and Foreign Income
Under the current MRA framework, individual income tax is calculated using the following bands:
- the first MUR 500,000 of annual chargeable income at 0%;
- the next MUR 500,000 at 10%; and
- the remainder at 20%.
Certain high-income individuals are currently also subject to the Fair Share Contribution regime where the relevant income threshold exceeds MUR 12 million.
Budget 2026/27 announced a proposal to introduce a 35% income tax band on chargeable income exceeding MUR 12 million and to replace the Fair Share Contribution for individuals. Investors and individuals relocating to Mauritius should verify the implementation date and final legislative provisions when planning their tax affairs.
The taxation of foreign income also requires careful analysis. A resident individual may be taxable in Mauritius on Mauritius-source income and on certain foreign income remitted to Mauritius, depending on the nature and circumstances of the income.
Foreign income should therefore be reviewed on a case-by-case basis rather than assuming that all offshore income is automatically exempt.
A Treaty Network of 45 Double Taxation Agreements
Mauritius has an extensive network of 45 Double Taxation Agreements, covering key investment markets including France, the United Kingdom, China, India, South Africa and the United Arab Emirates, as well as a growing number of African jurisdictions.
For international investors using Mauritius as a base for cross-border investment, these treaties can provide three important benefits:
- Reduced withholding taxes on dividends, interest and royalties arising in the investment jurisdiction, subject to the terms of the relevant treaty;
- Allocation of taxing rights between Mauritius and the other contracting state, helping to prevent the same income from being taxed twice; and
- Foreign tax relief or tax credits, where tax has already been suffered in the source jurisdiction.
Treaty benefits, however, are not automatic. A Mauritius entity seeking treaty relief must establish its tax residence in Mauritius and will generally need a valid Tax Residence Certificate (“TRC”). For companies holding a Global Business Licence, TRC applications are referred to the Financial Services Commission before being processed by the Mauritius Revenue Authority.
Just as importantly, modern treaty rules increasingly look beyond incorporation. Central management and control, commercial substance, beneficial ownership and anti-abuse provisions can all influence whether treaty benefits are available. Mauritius therefore works best not as a simple treaty-routing jurisdiction, but as a platform where genuine management, governance and economic activity are built into the structure from the outset.
How to Become a Tax Resident of Mauritius
Mauritius tax residency operates at two levels — individual and corporate — and the applicable tests are different. Immigration residence should also be distinguished from tax residence: having the right to live in Mauritius does not, by itself, make an individual tax resident.
The 183-Day Rule and the Tax Residence Certificate
An individual may qualify as tax resident in Mauritius where he or she:
- is domiciled in Mauritius, unless the permanent place of abode is outside Mauritius;
- is physically present in Mauritius for 183 days or more during an income year; or
- is physically present in Mauritius for an aggregate of 270 days or more during that income year and the two preceding income years.
There is no minimum investment requirement attached to these tax-residence tests themselves.
An individual who meets the applicable conditions may apply to the Mauritius Revenue Authority (MRA) for a Tax Residence Certificate (TRC). The TRC provides formal evidence of Mauritian tax residence and may be required by foreign tax authorities, financial institutions or other counterparties, particularly where treaty benefits are being claimed.
For international investors relocating to Mauritius, however, establishing Mauritian residence is only one side of the equation. The rules of the country being left must also be considered. Domestic residence tests, split-year treatment, exit taxes and continuing connections with the former jurisdiction can affect when — or whether — the previous tax residence actually terminates.
A properly planned relocation therefore looks at both jurisdictions before the move takes place.
Residence Permits: Investor, Professional, Self-Employed, Retired, Premium Visa, Golden Visa and Residence Through Property Investment
Tax residence determines how an individual is treated for tax purposes; an immigration permit determines the legal right to live and, where applicable, work or conduct business in Mauritius.
The principal routes available to international investors and professionals include:
- Occupation Permit – Investor: designed for non-citizens establishing and operating a business in Mauritius. Following the latest reforms, the minimum initial investment is USD 100,000, together with prescribed business-performance requirements for continued eligibility and renewal.
- Occupation Permit – Professional: available to non-citizens employed by a Mauritian entity. The current framework provides for a minimum basic monthly salary of MUR 50,000, subject to the applicable immigration requirements.
- Occupation Permit – Self-Employed: intended for non-citizens carrying on a professional or service activity on their own account. Continuing eligibility is linked to prescribed business-income requirements.
- Residence Permit – Retired Non-Citizen: available from age 50, subject to prescribed transfers of funds into Mauritius and the applicable residence conditions.
- Premium Visa: designed principally for individuals wishing to stay in Mauritius while working remotely or deriving their main income from outside the country. Its tax treatment is subject to specific rules governing foreign income and remittances into Mauritius.
- Golden Visa – a new investment-based route for high-net-worth individuals, requiring a commitment to invest at least USD 1 million within 12 months in qualifying sectors and providing a pathway to Permanent Residence.
- Residence through Property Investment: qualifying non-citizens purchasing residential property above the prescribed investment threshold under an approved property scheme may obtain residence rights, subject to the conditions of the relevant scheme.
Depending on the category, qualifying dependants may also obtain residence rights. Certain permit holders may subsequently qualify for longer-term or permanent residence where the applicable statutory conditions are satisfied.
The important distinction remains simple: an immigration permit gives the right to reside in Mauritius; tax residence determines the individual’s position under Mauritius tax law.
Corporate Residency and Economic Substance
Corporate tax residence requires a more careful analysis.
A company incorporated in Mauritius is generally resident for tax purposes, subject to statutory exceptions. In particular, a Mauritius-incorporated company that is centrally managed and controlled outside Mauritius may be treated as non-resident — the model under which an Authorised Company operates.
For a company holding a Global Business Licence (GBL), genuine presence in Mauritius is particularly important. Depending on the nature of its activities, this may involve appropriate Mauritius-resident directors, strategic decision-making in Mauritius, local administration, proper accounting records, banking arrangements and sufficient expenditure, personnel or other resources to support its activities.
Economic substance should not be approached as a compliance formality. The objective is to demonstrate that the company’s Mauritius presence reflects the commercial reality of the structure.
This becomes particularly important when a company seeks a Tax Residence Certificate or claims benefits under one of Mauritius’ Double Taxation Agreements. Foreign tax authorities may examine where strategic decisions are actually taken, who exercises control over the company, where its activities are performed and whether the structure has a genuine commercial purpose.
Substance is therefore best designed into the structure from the beginning rather than reconstructed when a tax authority asks questions.
Company Structures Available to Foreign Investors
Three corporate vehicles cover many of the structures used by international investors in Mauritius. The appropriate choice depends principally on where the business is conducted, where management and control are exercised, the nature and source of income and whether access to Mauritius’ treaty network is required.
1. Domestic Company
A domestic company is incorporated under the Companies Act 2001 and can generally be wholly foreign-owned, subject to restrictions applicable to particular regulated activities or sectors.
It is commonly used where the underlying activity is carried out substantially in Mauritius — for example, local services, technology, manufacturing, hospitality or other operating businesses.
Incorporation itself can generally be completed relatively quickly once the required information and documentation are available. Depending on the activity, however, additional licences, registrations or regulatory approvals may be required before operations begin.
A domestic company is subject to Mauritius corporate taxation and the applicable annual corporate tax and regulatory filing requirements.
2. Global Business License Company
The Global Business Licence is one of the principal vehicles used for cross-border investment through the Mauritius International Financial Centre.
A Global Business Licence is a Mauritius-resident corporation licensed by the Financial Services Commission and is generally used for business conducted principally outside Mauritius. Typical applications include international holding structures, investment vehicles, treasury operations, cross-border trading and other internationally focused activities.
Subject to satisfying the relevant statutory conditions, qualifying categories of foreign-source income may benefit from the 80% partial exemption, producing an effective corporate tax rate of 3% on that qualifying income.
A qualifying Global Business Licence may also obtain a Tax Residence Certificate and, subject to the provisions of the relevant treaty and applicable anti-abuse requirements, access Mauritius’ network of Double Taxation Agreements.
These advantages come with additional regulatory obligations. A Global Business Licence is subject to FSC supervision and must maintain appropriate substance, governance, administration, accounting and audit arrangements in Mauritius.
For substantial international structures, these requirements provide credibility as much as compliance. For very small or straightforward activities, however, the additional regulatory cost should be weighed against the actual benefits required from the structure.
3. Authorised Company
An Authorised Company is incorporated in Mauritius but is required to conduct business principally outside Mauritius and have its central management and control outside Mauritius.
For Mauritius income-tax purposes, an AC meeting those conditions is treated as non-resident. It is therefore generally taxable in Mauritius only to the extent that it derives income from Mauritius.
The trade-off is important: because the company is not Mauritius tax resident, it does not ordinarily obtain a Mauritius Tax Residence Certificate or benefit from Mauritius’ Double Taxation Agreement network.
An AC can therefore be appropriate for certain international trading, consultancy or asset-holding structures where treaty access is not required and management genuinely takes place outside Mauritius.
It remains, however, a Mauritius-incorporated company subject to corporate, regulatory, AML/CFT and filing requirements and must operate through a licensed management company acting as its registered agent.
What Changed in 2025-2026: Finance Act 2025
Recent reforms have made the distinction between genuine investment and passive residence increasingly important.
Among the changes relevant to international investors are:
- Property acquisition costs: registration duty applicable to non-citizens acquiring qualifying residential property under specified approved schemes increases from 5% to 10% for deeds registered on or after 1 July 2026. The precise treatment depends on the property and scheme involved.
- Smart City incentives: a number of fiscal incentives previously available to new Smart City projects have been withdrawn or restricted, with transitional provisions applying to qualifying existing projects.
- Occupation Permits: eligibility criteria have been revised. Under the latest framework, the Investor category requires an initial investment of USD 100,000, while the Professional category carries a minimum basic monthly salary of MUR 50,000. Business-performance requirements also apply to Investor and Self-Employed categories.
- Greater emphasis on substance and sustainable activity: the policy direction continues to favour businesses and investors demonstrating genuine economic participation rather than structures established solely to obtain a tax or residence advantage.
The core attraction of Mauritius nevertheless remains: a competitive corporate tax regime, access to an extensive treaty network, no general capital gains tax, no inheritance or estate tax and an established international financial-services framework.
The direction of travel is equally clear: Mauritius continues to welcome international capital, but increasingly rewards structures backed by genuine activity, governance and substance.
How MGM Supports Investors in Mauritius
As a licensed Management Company operating in Mauritius, MGM Management Ltd assists international founders, investors and families throughout the structuring and establishment process.
Our services include:
- assessing the appropriate structure — Domestic Company, Global Business Licence or Authorised Company — against the proposed business model, income flows and investment objectives;
- company incorporation and FSC applications;
- establishing appropriate governance and substance arrangements in Mauritius;
- assistance with corporate bank-account applications;
- accounting, administration, audit coordination and statutory filings; and
- coordination of residence and investment requirements for shareholders and their families.
The objective is not simply to incorporate a company, but to establish a structure that is commercially appropriate, operationally workable and capable of meeting ongoing regulatory requirements.
Contact MGM Management Ltd to discuss the structure most appropriate to your investment or international business activities.
Frequently Asked Questions
Is Mauritius a Tax Haven?
Mauritius operates as a regulated International Financial Centre, with corporate taxation, regulatory supervision, exchange-of-information mechanisms, AML/CFT requirements and economic-substance standards.
Its international proposition is based increasingly on tax efficiency combined with substance and regulatory credibility, rather than secrecy.
For investors, this distinction matters. A well-structured Mauritius vehicle should be capable of explaining its commercial purpose, identifying its beneficial owners, demonstrating where decisions are taken and complying with applicable tax and regulatory reporting requirements.
How Long Does Company Setup Take?
A straightforward domestic company can generally be incorporated within a few business days once all required information and documentation are complete.
A Global Business Licence involves an additional FSC licensing process, including review of the proposed activity, ownership, business plan and governance arrangements. The overall timeframe therefore depends on the complexity of the structure and the completeness of the application.
Bank-account opening is a separate process and remains subject to the financial institution’s own KYC, AML/CFT, source-of-funds and business-risk assessment.
For an international structure requiring both regulatory approval and banking arrangements, investors should therefore plan in weeks rather than days, with more complex structures potentially requiring longer.
Do Residents Pay Tax on Foreign Income?
The answer depends on the nature and source of the income and whether it is received or remitted into Mauritius.
Mauritius-resident individuals are taxable on income derived in Mauritius and subject to the applicable provisions of the Income Tax Act, foreign income remitted to Mauritius.
Special rules apply to certain categories, including holders of a Premium Visa. Remote-working income, transfers into Mauritius and expenditure through foreign payment cards can receive different treatment under the legislation.
Foreign income should therefore be analysed by category rather than assuming that all worldwide income is either automatically taxable or automatically exempt.
What Substance Does a GBL Company Need?
There is no single substance formula suitable for every GBL. The appropriate level of presence depends on the company’s activities and the income it earns.
Relevant factors can include Mauritius-resident directors, strategic decision-making in Mauritius, local administration and accounting records, appropriate banking arrangements, expenditure and — where required by the particular activity — employees, premises and core income-generating activities in Mauritius.
The practical question is straightforward:
Can the company demonstrate that its Mauritius presence is genuine and proportionate to the business it claims to conduct from Mauritius?
Where treaty benefits or the partial exemption are important to the structure, that question becomes particularly significant.
Can Buying Property Lead to Residency?
Yes. A non-citizen acquiring qualifying residential property under an approved Mauritius property scheme may obtain a residence permit where the applicable minimum investment and other statutory requirements are satisfied.
For example, qualifying property acquired under the Property Development Scheme can provide residence rights where the prescribed investment threshold is met.
Property ownership and tax residence should nevertheless be treated separately. Buying qualifying property may provide immigration residence, but it does not automatically establish Mauritius tax residence. The individual must separately satisfy one of the tax-residence tests, including the applicable physical-presence requirements.
Investors should also take acquisition costs into account. From 1 July 2026, the registration duty applicable to qualifying residential acquisitions by non-citizens under the relevant schemes increases from 5% to 10%.