Mauritius

Corporate taxation

The Corporate Tax Rate in Mauritius is 15 %.

Transfer pricing

Mauritius does not have any specific transfer pricing legislation. However, there is an arm’s-length provision in section 75 of the Income Tax Act requiring transactions between related parties to be priced at arm’s length.

Excerpt from Supreme court judgement, 2023 SCJ 73

“…by virtue of its title, section 75 is meant to incorporate in our main tax legislation the application of the arm’s length principle to business transactions for the purpose of assessment of liability to income tax. Furthermore, the arm’s length principle is one which is widely accepted and applied to both domestic and international business transactions. It implies that the parties in a particular transaction act independently in their own self-interest to achieve the most beneficial deal in the sense of a deal which closely matches a fair market value.”

Furthermore Part Vll of the Income Tax Act contains certain anti-avoidance provisions.

Mauritius enacted Country-by-Country Reporting Regulations (CbCR) on 19 February 2018. These regulations are effective for covered MNE groups for FY beginning on or after 1 July 2018.

Links

Transfer Pricing Case Law

Case NameDescriptionDateCountryKeywords