The Mauritius Revenue Authority (“MRA”) applies the Income Tax Act 1995 (“ITA 1995”) to ensure that taxpayers comply with filing of their annual income tax returns and pay their taxes on time. According to the ITA 1995, penalties and interests are imposed where the taxpayer fails to abide by the prescribed due date. Moreover, the purpose of penalty is for non-compliance while the interests compensate...
As the annual tax filing season for individuals approaches, it is important for these individuals to understand their obligations under the Mauritius Income Tax Act 1995. Whether a person is filing his income tax return for the first time or seeking to ensure compliance with the latest requirements, it is important to have a clear understanding of residency status, filing obligations, available reliefs...
The Indian Supreme Court’s ruling in Tiger Global represents a significant shift in international tax jurisprudence involving the India–Mauritius treaty. For years, Mauritius has been a key hub inbound investment structures, supported by a favourable Double Taxation Avoidance Agreement, a stable regulatory regime, and the long standing belief that a Tax Residency Certificate (TRC) issued by the Mauritius...
The concept of Permanent Establishment (PE), long regarded as a cornerstone of international tax law, is undergoing rapid transformation as courts across jurisdictions adopt broader, substance oriented interpretations. With the rise of digital business models and increasing cross border service delivery, recent rulings in India and Germany signal a decisive shift toward expanding taxing rights based...
In today’s highly interconnected world—where businesses operate across borders and corporate governance routinely extends beyond a single jurisdiction—determining a company’s tax residence has become a central issue in international tax administration. Two key concepts sit at the core of this analysis: Central Management and Control (CMC) and the Place of Effective Management (POEM). Although people...
The decision in Indys Co Ltd v Director General, Mauritius Revenue Authority raises important conceptual issues concerning the scope of the statutory duty to give reasons within Mauritius’ tax objection framework. The Tribunal’s ruling provides clarity on the degree of specificity required under section 7C of the Mauritius Revenue Authority Act (“MRA Act”) and delineates the boundaries of the deemed...
The global tax landscape is changing at a remarkable pace. Cross border business activity continues to expand, multinational groups are structuring themselves in increasingly complex ways, and tax authorities around the world have become far more assertive. As a result, disputes over taxing rights are rising sharply. In this environment, the Mutual Agreement Procedure (MAP)—set out in Article 25 of...
1. Introduction This report provides an analytical overview of the two 2025 Federal Court decisions involving Shopify Inc., namely 2025 FC 969 and 2025 FC 968. Both cases concern applications by the Minister of National Revenue for judicial authorization to issue Unnamed Persons Requirements (UPRs) compelling Shopify to disclose information relating to individuals or businesses using its platform....
Effective 1 January 2026, Mauritius will start applying VAT at the standard rate of 15% to digital and electronic services supplied by foreign suppliers. This applies even where the foreign supplier does not have an office, employees, or any physical presence of any sort in Mauritius.
Mauritius Launches Revenue Tribunal: A New Era for Tax Appeals
Introduction
Background
The expansion of digital communication and remote working arrangements has reshaped how professional services are delivered across borders. Consultants based overseas can advise Mauritian entities without ever setting foot in the country. While this evolution presents efficiencies and opportunities, it also introduces complex tax considerations that must be addressed with clarity.
By Forvis Mazars Mauritius – January 2026
The German Supreme Tax Court's recent decision to refuse leave to appeal in the landmark "locker case" has fundamentally altered the landscape of permanent establishment (PE) determination under international tax law. This ruling, which upheld a lower court's finding that a simple storage locker can constitute a fixed place of business under Article 5 of the German-UK double tax treaty, represents...
Stay informed about the latest legal developments in Mauritius' tax landscape. This article provides a detailed analysis of recent tax-related court cases, highlighting key decisions and their implications. From expatriate employee benefits to VAT treatment of services, gain insights that could impact your tax strategy.
Mauritius has established itself as a reputable and competitive international financial centre, underpinned by a robust legal and regulatory framework. A cornerstone of its corporate tax regime is the Partial Exemption System, introduced through the Finance Act 2018 and codified in the Income Tax Act 1995. This regime provides for an 80% exemption on specified categories of income, thereby significantly...
Tax treaties, particularly Double Taxation Avoidance Agreements (DTAAs), are pivotal tools in the realm of economic diplomacy. They facilitate cross-border trade and investment, reduce fiscal barriers, and promote bilateral cooperation. Mauritius, a strategically located island nation off the eastern coast of Africa, exemplifies the strategic use of tax treaties to position itself as a premier financial...
With the end of June 2025, the statutory deadline to file returns has lapsed. You have missed any returns?
IFRS 16 is more than just an accounting standard—it’s a game-changer in how companies report their leasing obligations. Introduced by the International Accounting Standards Board (IASB), IFRS 16 requires lessees to bring most leases onto the balance sheet, fundamentally altering the financial landscape for businesses across industries.
In a significant legislative development, the Goverment of Mauritius will present the Revenue Tribunal Bill (No. XII of 2025) in parliament soon, , would mark a transformative shift in the country’s tax dispute resolution framework. The proposed legislation seeks to replace the existing Assessment Review Committee with a newly constituted Revenue Tribunal, with the aim of streamlining the appeals...
Stay informed about the latest legal developments in Mauritius' tax landscape. This article provides a detailed analysis of recent tax-related court cases, highlighting key decisions and their implications. From expatriate employee benefits to VAT treatment of services, gain insights that could impact your tax strategy.
In a groundbreaking decision that could reshape the landscape of international tax litigation, the Swedish Supreme Administrative Court has affirmed the right of taxpayers to seek judicial review of treaty-based transfer pricing adjustments. Delivered on November 25, 2024, in the case of Played Holding AB v. Skatteverket, the ruling confirms that Swedish administrative courts have jurisdiction to...
Important Monthly Tax Deadlines Are Approaching! Don’t Miss Out!
In this edition we will analyze two income tax rulings, specifically TR 280 and TR 283.
Understanding the Climate Challenge
Depreciation is an accounting method used to allocate the cost of a tangible fixed asset over its useful life. The fundamental principle is that assets such as machinery, vehicles, buildings, and equipment provide economic benefits to a business over multiple years, rather than solely in the year of acquisition. Consequently, instead of expensing the entire cost of an asset in the year it is purchased,...
In the digital age, multinational tech giants generate vast revenues from users across the globe—often without a physical presence in the countries where their services are consumed. The rapid developments in the digital economy have outpaced international tax laws, resulting in some companies exploiting tax loopholes and mismatches in rules between countries to avoid taxes. This has led to growing...
As the end of May 2025 approaches, here’s what you need to ensure is completed for the month:
In an increasingly interconnected global economy, robust international tax reporting is essential for jurisdictions committed to fostering transparency and ensuring the effective application of their domestic tax laws. Mauritius, as a prominent international financial centre, is fully engaged in this global effort. The nation's international tax reporting framework stands as a critical pillar of its...
Important Monthly Tax Deadlines Are Approaching! Don’t Miss Out!
Stay informed about the latest legal developments in Mauritius' tax landscape. This article provides a detailed analysis of recent tax-related court cases, highlighting key decisions and their implications. From expatriate employee benefits to VAT treatment of services, gain insights that could impact your tax strategy.
Mauritius has established itself as a prominent business hub in Africa and Asia, attracting significant investment with various incentives. However, engaging in international trade from Mauritius necessitates managing currency risk, as fluctuations in exchange rates can impact profitability. Foreign exchange differences, resulting from variations in currency values influenced by economic and political...
Interest deductibility has emerged as a significant issue within the complex landscape of corporate taxation in Mauritius. Understanding its intricacies is crucial for businesses.
Stay informed about the latest legal developments in Mauritius' tax landscape. This article provides a detailed analysis of recent tax-related court cases, highlighting key decisions and their implications. From expatriate employee benefits to VAT treatment of services, gain insights that could impact your tax strategy.
Transfer pricing is an important yet relatively underexplored aspect of taxation in Mauritius. Currently, the country lacks a detailed set of specific transfer pricing regulations and depends instead on a general arm's length provision within its legal framework. Nonetheless, the Mauritius Revenue Authority (MRA) has launched numerous tax audits and assessments focusing on transfer pricing, frequently...
Navigating the landscape of international tax compliance is no simple task. It requires substantial resources to unravel its complexities and ensure adherence to local regulations across the globe.
As the end of April 2025 approaches, here’s what you need to ensure is completed for the month:
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