モーリシャスの法人税務
競争力ある15%表面税率、対象外国所得への寛大な部分免除制度、簡単な申告義務により、モーリシャスは国際持株・運営会社にとって最も税務効率の高い管轄区域の一つとなっています。
モーリシャスは純所得に対して均一税率15%の属地主義法人税制を運営しています。対象外国源泉所得（配当、利息、ロイヤリティ、譲渡益）を得る会社の場合、部分免除制度によりその所得フローの実効税負担は3%以下に低下します。
Tax Rates and Regimes
Standard Corporate Tax Rate
A flat 15% rate applies to all companies incorporated or tax-resident in Mauritius on their chargeable income. This rate applies uniformly regardless of company size or sector, providing certainty for planning purposes.
Partial Exemption Regime
Global Business Companies (GBCs) and other qualifying entities may claim an 80% partial exemption on specified foreign-source income, reducing the effective rate to 3%. Qualifying income categories include foreign dividends, interest, royalties, gains on disposal of securities and income from collective investment schemes.
Participation Exemption
Dividends received by a Mauritius company from a foreign subsidiary are fully exempt from tax where the Mauritius company holds at least 5% of the share capital of the subsidiary, or where the dividends are subject to tax in the source country. This participation exemption makes Mauritius an effective intermediate holding location.
Capital Gains Tax
Mauritius does not levy capital gains tax. Gains on the sale of shares, real estate (outside Mauritius) and other assets held through a Mauritius company are not subject to tax at the corporate level, making the jurisdiction attractive for private equity, real estate and venture capital structures.
Solidarity Levy
A 25% solidarity levy applies to certain companies with gross income exceeding MUR 3 billion derived from specific regulated banking activities. This does not affect the vast majority of international holding or operating companies.
Corporate Tax Filing and Compliance
Tax Registration
All companies must register with the Mauritius Revenue Authority (MRA) upon incorporation. A Tax Account Number (TAN) is issued and the company is registered for corporate tax purposes. We manage this registration as part of the incorporation process.
Advance Payment System (APS)
Companies with annual chargeable income above MUR 10 million are required to make quarterly advance tax payments under the Advance Payment System. Payments are due in the sixth, ninth and twelfth months of the accounting year, with a balance payment upon filing of the annual return.
Preparation of Financial Statements
Companies must prepare annual financial statements in accordance with International Financial Reporting Standards (IFRS) or IFRS for SMEs, depending on size. These are required to support the annual tax return and, for GBCs, to comply with FSC reporting requirements.
Annual Tax Return (IT Return)
The annual income tax return (Form IT) must be filed with the MRA within six months of the company's accounting year-end. The return discloses chargeable income, applicable exemptions and credits, and the final tax liability for the year.
Partial Exemption Claim
Where the partial exemption regime applies, a specific claim must be made on the tax return with supporting documentation demonstrating that the income qualifies under the applicable category. Our team prepares and reviews these claims to ensure compliance and maximise the available relief.
Transfer Pricing and Substance
Mauritius has adopted OECD-aligned transfer pricing rules. Related-party transactions must be conducted at arm's length and documented. For GBC structures, adequate economic substance must be demonstrated through local management and control, board meetings in Mauritius and core income-generating activities.
Key Compliance Requirements
- Annual income tax return filed within 6 months of financial year-end
- Quarterly APS payments for companies with chargeable income above MUR 10 million
- IFRS-compliant financial statements prepared annually
- Transfer pricing documentation for related-party transactions
- Economic substance requirements for GBC licence holders
- VAT registration required if annual turnover exceeds MUR 6 million
- Employer monthly PAYE and NPF/NSF returns where staff are employed in Mauritius
- Country-by-Country Reporting (CbCR) for MNE groups with consolidated turnover above EUR 750 million
Indicative Costs for Tax Compliance Services
| Item | Indicative range |
|---|---|
| Annual tax return preparation (simple GBC) | USD 800 – 1,500 |
| Annual tax return preparation (complex / multiple income streams) | USD 1,500 – 3,500 |
| Partial exemption claim preparation and review | USD 500 – 1,200 |
| Transfer pricing documentation (per year) | USD 2,000 – 6,000 |
| MRA query / audit support (per engagement) | USD 1,500 – 5,000 |
| VAT registration and ongoing compliance | USD 600 – 1,500 per year |