Resident companies are subject to tax on their worldwide income. Taxable income is gross trading and investment income less any expenses and other allowances incurred for the production of taxable income.

Effective 1 July 2020, small enterprises have the option to be taxed under the presumptive taxation regime. Small enterprise means a person:

Engaged in agriculture, forestry and fishing, manufacturing (excluding restaurants), retail and wholesale of goods etc.;
Having gross income up to MUR 10 million; and
Whose income from other sources does not exceed MUR 400,000.

Mauritius revamped its international tax infrastructure in 2019. Prior to the changes, the country had principally two corporate forms for structuring international business: the GBL1 and GBL2 companies. GBL1 entities were taxable (with a (deemed) foreign tax credit), and resident, whilst GBL2 entities were exempt from tax and non-resident (see below). The GBL1/GBL2 status has been replaced by a new GBL status, whereby the relevant entity is subject to tax on worldwide income, but is eligible for a generic 80% exemption on qualifying foreign-sourced income (see Sec. 5.2.) and treated as a resident if meeting prescribed economic substance tests. Concurrently, a new “Authorized Company” form was introduced. This type of entity is subject to tax only on Mauritian sourced income as prescribed and is generally treated as a non-resident.

GBL1/GBL2 and GBL Entities

Prior to the 2019 changes, Global Business License companies (GBL1) were subject to regular corporate tax on worldwide income but could claim a credit equal to either the foreign tax paid or 80% of the Mauritius tax on the foreign income, whichever is higher. Effective 1 January 2019, the credit regime has been abolished, consequent to the introduction of the new Global Business License (GBL) regime (see Sec 3.1. above). Nevertheless, under a grandfathering regime, companies registered as GBL1 with license issued on or before 16 October 2017 continue to be covered by the erstwhile credit regime until 30 June 2021 (companies with license issued post 16 October 2017 were eligible until 31 December 2018) and will be deemed as Global Business License (GBL) thereafter.

GBL2 companies, are fully exempt from tax until 30 June 2021 (or 31 December 2018, depending on the date of issue of their license), and are subsequently required to register as an Authorized Company or GBL or apply for dissolution.

Authorized Company Foreign-sourced income of the company is not taxable in Mauritius, whereas Mauritian sourced income is generally taxable, and annual returns must be submitted (a registered agent must be appointed in Mauritius at all times).

Dividends

Dividends received from Mauritius companies are excluded from taxable income. Foreign-source dividends are assessed to tax with a credit for the foreign underlying tax and withholding tax, if any. Foreign-source dividends were (or still are to the extent grandfathered, see above) eligible for the GBL1 deemed credit system. See further Sec. 5.2.

Capital Gains

There is no tax on capital gains in Mauritius (including gains on the sale of securities and precious metals such as gold, silver, platinum), subject to exceptions where certain transactions are considered as ordinary business income instead of capital gains. Gains derived from the sale of shares or securities held for less than 6 months in the course of the business of trading in such instruments are treated as business profits and subject to income tax.

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