毛里求斯实体的CRS和FATCA合规
毛里求斯是全球自动信息交换框架的坚定参与者。了解您在CRS和FATCA下的申报义务并维护合规架构，对每一个毛里求斯公司、信托及基金至关重要。
共同申报准则（CRS）和美国《外国账户税收合规法》（FATCA）是影响毛里求斯架构的两个主要自动信息交换制度。毛里求斯签署了OECD关于CRS的多边主管当局协议，并在FATCA下与美国签订了政府间协议（IGA）。符合任一制度下申报金融机构定义的金融机构、控股公司、信托及基金必须登记、识别应报告账户持有人，并向毛里求斯税务局（MRA）提交年度报告。
CRS and FATCA — Key Concepts
Common Reporting Standard (CRS)
CRS is the OECD's global standard for automatic exchange of financial account information between tax authorities. Over 100 jurisdictions participate. Mauritius financial institutions must identify account holders who are tax resident in any CRS-participating jurisdiction and report their account details and balances annually to the MRA, which then exchanges this information automatically with the relevant foreign tax authorities.
FATCA (US Foreign Account Tax Compliance Act)
FATCA requires foreign financial institutions to identify and report on accounts held by US persons (citizens, residents, and entities with substantial US ownership). Mauritius has a Model 1 IGA with the United States, meaning Mauritius financial institutions report to the MRA, which in turn reports to the IRS. Non-compliant institutions face 30% withholding on US-source payments.
Who is a Reporting Financial Institution?
Under both CRS and FATCA, the definition of Financial Institution (FI) is broad and includes not just banks, but also custodial institutions, investment entities (including many trusts and holding companies that are managed by other FIs), and specified insurance companies. The classification of each Mauritius entity must be carefully assessed — many GBCs and trusts qualify as Investment Entities and therefore as FIs.
Investment Entity Classification
A Mauritius holding company or trust that is managed by a professional financial institution and whose assets consist primarily of financial interests is likely classified as an Investment Entity — and therefore a Reporting Financial Institution. This means it must register with the MRA, perform due diligence on its account holders (shareholders, beneficiaries), and submit annual returns.
Non-Reporting FIs and Exempt Products
Certain entities qualify as Non-Reporting Financial Institutions or Exempt Products under CRS or FATCA — including certain retirement funds, governmental entities, international organisations, and certain collective investment vehicles. Classification requires careful analysis. Incorrectly treating a reportable entity as exempt creates significant compliance risk.
Penalties for Non-Compliance
Under Mauritius law, failure to register, submit returns, or maintain adequate due diligence documentation can result in administrative penalties imposed by the MRA. Additionally, under FATCA, non-compliant institutions face 30% withholding on US-source income. Reputational consequences with banking counterparties and institutional investors can be equally significant.
Our CRS / FATCA Compliance Process
Entity Classification
We assess the classification of each Mauritius entity under both CRS and FATCA — determining whether it is a Reporting FI, Non-Reporting FI, Active Non-Financial Entity (NFE), or Passive NFE. This classification drives all subsequent obligations.
FATCA Registration
Where required, we register the entity on the IRS FATCA Registration Portal to obtain a Global Intermediary Identification Number (GIIN). This is required for all Participating Foreign Financial Institutions and must be renewed and maintained annually.
MRA Registration
We register the entity with the MRA as a Reporting Financial Institution for CRS and/or FATCA purposes, ensuring the entity appears on the MRA's register and receives access to the online reporting portal.
Due Diligence on Account Holders
We implement the required CRS and FATCA due diligence procedures — collecting self-certification forms from account holders, reviewing existing documentation, identifying reportable persons, and applying the relevant pre-existing account and new account procedures.
Annual Reporting
We prepare and submit the annual CRS and FATCA returns to the MRA, disclosing reportable account holder information, account balances and income. Returns are due by 30 June of each year for the preceding calendar year.
Ongoing Monitoring and Policy Maintenance
We maintain a compliance calendar for each entity, monitor for changes in reportable status, update self-certifications as required, and ensure that internal policies and procedures reflect current regulatory guidance from the MRA and the OECD.
Key Documentation Requirements
- Self-certification forms from all account holders (shareholders, beneficiaries, controlling persons)
- Tax Identification Numbers (TINs) for all reportable persons
- Passports and proof of tax residence for natural persons
- Entity classification documentation (including beneficial ownership analysis for passive NFEs)
- GIIN registration confirmation (for FATCA-registered FIs)
- MRA Reporting FI registration confirmation
- Annual CRS and FATCA reports submitted to the MRA by 30 June
- Documented CRS/FATCA compliance policy and due diligence procedures