मॉरीशस कर सलाहकार सेवाएं
अंतर्राष्ट्रीय कर नियोजन, दोहरे कराधान समझौते के अनुप्रयोग और BEPS अनुपालन के लिए विशेषज्ञ परामर्श सेवाएं।
Our tax advisory services help international businesses, investors, and family offices optimise their tax position through Mauritius-based structures, within a fully compliant framework. We provide strategic advice on double taxation agreement (DTA) utilisation, partial exemption eligibility, transfer pricing policy, substance requirements, international tax structuring, and the tax treatment of complex transactions. Mauritius's tax framework — anchored by the Income Tax Act 1995 — offers genuine structural advantages: a 15% corporate tax rate, an 80% partial exemption on qualifying foreign-source income for GBCs, no capital gains tax, no withholding tax on outbound dividends, and a DTA network of over 45 treaties.
These advantages are real but require careful structuring and ongoing compliance to be effectively accessed. Our advisory engagements cover the full range of international tax issues: selecting the optimal Mauritius entity type, structuring investment holding chains for DTA efficiency, designing transfer pricing policies for intragroup transactions, advising on substance arrangements to support partial exemption claims, planning for the tax treatment of exits and asset disposals, and advising on the interaction between Mauritius tax law and the tax laws of the investor's or beneficiary's home jurisdiction. All advisory is grounded in applicable Mauritius law, OECD guidelines, and international best practices.
We do not recommend structures that are aggressive, abusive, or non-compliant with the economic substance requirements underpinning Mauritius's treaty network.
Key Features of Tax Advisory in Mauritius
DTA Utilisation Planning
We identify the optimal routing of investment flows through Mauritius to access DTA benefits — reduced withholding taxes on dividends, interest, royalties, and capital gains — from treaty partner countries. We ensure treaty benefit eligibility by confirming residency, substance, and beneficial ownership requirements.
Partial Exemption Eligibility Analysis
We assess the eligibility of each category of foreign-source income for the 80% partial exemption under the Income Tax Act 1995, advising on required substance arrangements and documenting the basis for the partial exemption claim in annual tax filings.
International Group Tax Structuring
We advise on the optimal use of Mauritius entities — GBC, Authorized Company, trust, or foundation — within international group structures, considering DTA access, tax efficiency, substance requirements, and operational practicality.
Transfer Pricing Advisory
We design transfer pricing policies for intragroup transactions that are commercially rational and OECD-compliant, prepare benchmarking studies to establish arm's length ranges, and prepare contemporaneous documentation to support the positions taken.
Substance Advisory and Implementation
We advise on the substance arrangements needed to support GBC licensing, DTA benefit claims, and partial exemption eligibility, and provide practical solutions for implementing substance — including staffing, office space, board meeting management, and expenditure planning.
Exit and Disposal Tax Planning
We advise on the tax treatment of planned asset disposals, business sales, and restructurings, identifying the most tax-efficient sequencing and structuring of transactions within the bounds of applicable law.
Anti-Avoidance Compliance
We ensure that structures and transactions are compliant with Mauritius anti-avoidance provisions and OECD BEPS standards, including the principal purpose test, limitation on benefits provisions in DTAs, and the requirement for genuine economic substance.
Ruling and Confirmation Applications
Where permitted, we assist with applications to the MRA for advance tax rulings or confirmations on the tax treatment of proposed transactions, providing certainty before committing to significant structuring decisions.
Cross-Border Tax Interaction Analysis
We analyse how Mauritius tax positions interact with the tax laws of other relevant jurisdictions — addressing questions of foreign tax credits, CFC rules, GAAR provisions, and hybrid mismatch arrangements that may apply in the investor's or beneficiary's home country.
Legislative Monitoring and Impact Assessment
We monitor changes in Mauritius tax legislation, MRA guidance notes, DTA renegotiations, and OECD/G20 developments, and assess their impact on existing structures, providing timely advice on any adjustments required.
How to Engage Tax Advisory in Mauritius
Briefing and Information Gathering
We conduct a detailed briefing to understand your business model, income flows, group structure, existing tax positions, and objectives. We request a group structure chart, details of income by type and source, and current tax positions in all relevant jurisdictions.
Tax Position Analysis
We analyse the applicable DTA provisions, partial exemption rules, transfer pricing requirements, and any anti-avoidance considerations that apply to your specific situation. We identify available planning opportunities and potential risk areas.
Cross-Jurisdiction Coordination
Where the advisory touches on the tax laws of other countries, we coordinate with local tax advisors in those jurisdictions to ensure the Mauritius structure is compatible with local tax treatment and does not create unintended tax liabilities elsewhere.
Written Advisory and Recommendations
We deliver a written advisory setting out our analysis, recommendations, implementation steps, and identified risks. The advisory is reviewed and approved by a senior tax professional before delivery.
Implementation Support
We support the implementation of the recommended structure — whether that involves entity formation, substance arrangements, transfer pricing documentation, or changes to existing corporate or trust structures — coordinating all aspects of the implementation process.
Compliance Integration
We integrate the advisory positions into the ongoing compliance framework — tax returns, APT calculations, CRS/FATCA reporting — ensuring consistency between advisory positions and annual compliance filings.
Transaction Support
For specific transactions — asset disposals, acquisitions, restructurings, or financing arrangements — we provide transaction-specific tax due diligence, structuring advice, and post-transaction implementation support.
Ongoing Monitoring
We provide ongoing monitoring of legislative and regulatory developments, alerting you to changes that may affect your tax position, and advising on any restructuring or compliance adjustments that may be required in response.
Requirements for Tax Advisory in Mauritius
- Group structure chart showing all entities, jurisdictions, and ownership percentages
- Details of all significant income flows (dividends, interest, royalties, fees, capital gains)
- Current tax position in all relevant jurisdictions and any existing ruling or confirmation letters
- Details of substance arrangements currently in place for Mauritius entities
- Existing intercompany agreements and transfer pricing documentation
- Target investment markets and counterparty jurisdictions
- Details of any planned transactions, restructurings, or asset disposals
- Financial statements of all relevant entities for the most recent period
- Tax residency certificates and existing DTA positions
- Details of any MRA correspondence, assessments, or pending tax issues
Estimated Costs of Tax Advisory in Mauritius
| आइटम | अनुमानित सीमा |
|---|---|
| Initial tax review and advisory memo | USD 1,500 – 5,000 |
| DTA structuring advisory | USD 2,000 – 7,000 |
| Transfer pricing policy design | USD 3,000 – 10,000 |
| Transaction tax advice (per transaction) | USD 2,000 – 10,000+ |
| पदार्थ सलाह और कार्यान्वयन योजना | USD 1,500 – 4,000 |
| चल रहे कर निगरानी रिटेनर (वार्षिक) | USD 2,000 – 6,000 |
Frequently Asked Questions About मॉरीशस कर सलाहकार सेवाएं
Can Mauritius reduce withholding taxes on dividends from India?
Mauritius has a Double Taxation Avoidance Agreement with India that provides for reduced withholding tax rates on dividends, interest, and certain other income. The rates applicable depend on the specific provisions of the DTA and the nature of the income. To claim DTA benefits, the Mauritius entity must be a genuine tax resident, meet substance requirements, and hold a valid Tax Residency Certificate. Professional advice is recommended to confirm treaty eligibility and benefits in each specific case.
Is tax advisory confidential?
Yes. All tax advisory engagements are subject to strict professional confidentiality obligations. We do not disclose client information, tax positions, or structure details to any third party without explicit written consent, except where required by Mauritius law or regulatory obligation. Confidentiality is a fundamental principle of our professional service.
How do you ensure compliance with OECD BEPS standards?
We ensure that all structures we advise on are compliant with OECD Base Erosion and Profit Shifting (BEPS) minimum standards. This includes advising on economic substance requirements, ensuring that DTA benefits are claimed only where genuine commercial activity supports the claim, documenting transfer pricing positions, and avoiding hybrid mismatch arrangements. We do not recommend structures that rely on form over substance.
What is the principal purpose test?
The principal purpose test (PPT) is an anti-avoidance provision included in most modern DTAs, including those negotiated under the OECD Multilateral Instrument. It provides that DTA benefits can be denied if one of the principal purposes of an arrangement was to obtain those benefits. We advise on structures that have genuine commercial substance so that DTA benefits can be claimed with confidence.
Can Mauritius be used for holding intellectual property?
Yes. A Mauritius GBC can hold intellectual property and receive royalties from IP licensees in DTA partner countries, with reduced withholding tax rates on royalties under applicable treaties. The GBC must meet substance requirements and the IP must be developed and managed from Mauritius to comply with OECD BEPS Action 5 on harmful tax practices. We advise on IP holding structures within a fully compliant framework.
What happens if Mauritius loses a DTA?
Mauritius has occasionally renegotiated or seen treaties suspended — for example, the amendment of the India DTA in 2016. We monitor the status of all relevant DTAs and alert clients immediately when changes are announced that may affect existing structures. Where a significant change occurs, we provide restructuring advice to adapt the structure to the new treaty landscape.
How does Mauritius interact with CFC rules in other jurisdictions?
Many countries — including the UK, France, Germany, and others — have Controlled Foreign Corporation (CFC) rules that may attribute the income of a foreign subsidiary to a parent company if the subsidiary is not genuinely conducting business. A Mauritius entity with adequate substance and genuine commercial activity is well positioned to withstand CFC analysis, but the application of CFC rules is highly jurisdiction-specific. We work with local advisors in the relevant country to assess CFC exposure.
Do you advise on the tax treatment of Mauritius trusts?
Yes. We advise on the Mauritius tax treatment of trust income, distributions, and settlements, as well as the interaction between the Mauritius trust framework and the tax laws of the settlor's and beneficiaries' jurisdictions. The tax treatment of trusts is complex and jurisdiction-specific, and professional advice in each relevant country is always recommended alongside our Mauritius advisory.