毛里求斯の国際税務計画は、40以上の二重課税防止条約ネットワーク、部分免除制度、キャピタルゲイン税の不在、非居住者への配当に対する源泉徴収税の不在を組み合わせたものです。毛里求斯は完全にOECD準拠であり、BEPSアクション計画の措置を実施しています。これにより、毛里求斯は積極的な脱税スキームではなく、真の経済活動のための租税効率化の拠点として認識されています。
Key Tax Planning Structures
Mauritius Holding Company
A Mauritius GBC holding shares in operating subsidiaries across Africa, Asia or the Middle East can benefit from treaty-reduced withholding taxes on dividends, interest and royalties flowing up from those subsidiaries. The 80% partial exemption then applies to qualifying foreign income received at the holding level, achieving effective rates of 3% or less. Capital gains on exit are exempt at the Mauritius level.
Treaty-Enhanced Investment into Africa
Mauritius has double taxation agreements with key African markets including South Africa, Kenya, Uganda, Rwanda, Zimbabwe, Senegal, Mozambique, Nigeria, Botswana and others. These treaties typically reduce or eliminate withholding taxes on dividends, interest and royalties that would otherwise apply under domestic law — creating a material after-tax uplift on returns from African investments.
IP Holding Structure
Intellectual property rights held by a Mauritius company can attract royalty income from group companies or licensees. Royalties received from non-residents qualify for the 80% partial exemption, and Mauritius's treaties often reduce withholding taxes in the source country. This structure is appropriate where IP has been legitimately developed or acquired and where the Mauritius company has genuine substance in managing the IP portfolio.
Debt Financing Vehicle
A Mauritius company can be used as a back-to-back financing vehicle, on-lending funds to operating companies in treaty partner countries at arm's length interest rates. Treaty provisions typically reduce withholding tax on interest below domestic rates, and the interest income received by the Mauritius vehicle qualifies for partial exemption. Appropriate transfer pricing documentation and economic substance are essential.
Regional Headquarters
Multinational groups with operations across Africa and Asia increasingly use Mauritius as their regional headquarters — concentrating management, finance, treasury, procurement and HR functions in a single, tax-efficient, English-speaking jurisdiction. The combination of treaty access, low tax, high-quality professional services and ease of doing business makes this a compelling operational choice, not just a tax-driven one.
Private Equity and Fund Structures
Private equity managers investing into African or Asian markets frequently structure their fund vehicles through Mauritius. The fund itself benefits from Mauritius's pass-through or exempt treatment for qualifying income, while the general partner entity and management company can benefit from the partial exemption and treaty network. The FSC provides a well-understood regulatory framework for such structures.
Our Approach to International Tax Planning
Objectives and Income Mapping
We begin by mapping the client's income flows, investment locations, existing structures and desired outcome. This allows us to identify where Mauritius adds genuine value as an intermediate or holding jurisdiction.
Treaty Analysis
We review the relevant double taxation agreements between Mauritius and the target investment jurisdictions, identifying the withholding tax rates applicable to dividends, interest and royalties, and the conditions that must be met to access treaty benefits.
Structure Design
We design a compliant, defensible structure that achieves the client's tax efficiency objectives while meeting the OECD's substance and anti-avoidance standards, including BEPS Actions 6 (treaty abuse) and 13 (CbCR).
Implementation
We manage the incorporation of the Mauritius holding or intermediate company, application for GBC licence, drafting of constitutional documents, appointment of directors, and opening of bank accounts.
Ongoing Substance and Compliance
We provide managed substance services including Mauritius-based directors, regular board meetings in Mauritius, economic substance monitoring, annual financial statements, tax return preparation and FSC annual filings.
Substance Requirements for Treaty Access
- Company must be tax resident in Mauritius — this requires management and control to be exercised in Mauritius
- Board of directors must include Mauritius-resident directors and meet regularly in Mauritius
- Core income-generating activities must be carried out in Mauritius or by Mauritius-based service providers
- Adequate local expenditure and qualified personnel (directly or through service providers)
- Principal place of business must be in Mauritius — registered office and operational presence required
- A Tax Residence Certificate (TRC) issued by the MRA is required to access treaty benefits — this requires demonstrating genuine substance
- For GBCs, annual certificate of tax residence and FSC annual return must be maintained
- Transfer pricing rules require that cross-border related-party transactions are at arm's length