Mauritius Is Not an Offshore Jurisdiction – and Other Tax “Surprises” of This Country

We are seeing Mauritius used increasingly often in the structures and business models of our clients. This is not surprising: the country has a long-standing reputation as a business-friendly jurisdiction, especially for structuring assets and operating in Asian and African markets. Its absence from Russia’s list of “unfriendly” jurisdictions also adds to its appeal.

At the same time, the tax rules in Mauritius – once perceived as a tax haven – have been evolving rapidly. To keep Mauritian structures efficient, a nuanced setup is now required.

For example, it is necessary to take into account that:

• Mauritius applies a 15% corporate income tax rate, and from 2025 year introduced Domestic Minimum Top-up Tax (DMTT) under the global tax reform.
• Foreign dividends are not fully exempt from tax (which is unusual given the widespread use of participation exemption regimes in other countries).
• Mauritius has implemented CFC rules, and the profits of Mauritian companies are subject to additional levies – CCR and CSR.

At the same time, the jurisdiction offers multiple preferential regimes – from Global Headquarters to tax exemptions for Authorized Companies, as well as an 80% exemption for certain interest income. This requires careful design of Mauritian structures.

You can find more details on these and other tax features of Mauritius in our overview: