About Mauritius

Taxation

A Guide to Taxation in Mauritius

Mauritius has one of the lowest tax regimes in the world. Both corporate and individual income is taxed at 15%. The island boasts an extensive network of double tax treaties and offers major incentives to offshore companies resident in Mauritius for tax purposes.
Tax Situation
  • Global Business Licence (GBC) company pay an annual licence fee of USD 1,950 and a one-off licence application fee of USD 500 to the FSC and USD 250 on incorporation and USD 325 annually to the Registrar of Companies. Global Business Licence (GBC) Companies are resident in Mauritius for tax purposes and are not subject to capital gains taxation and there are no withholding taxes on the payment of dividends, interest or royalties from Companies of the same status. There are no stamp duties or capital taxes. Global Business Licence (GBC) companies are liable to taxes at a rate of 15%.
  • Provided that the Global Business Licence (GBC) company owns at least 5% of an underlying company, credit will be available on foreign tax paid on the income out of which the dividend was paid (“underlying foreign tax credit”).
  • When a company not resident in Mauritius, which pays a dividend has itself received a dividend from another company not resident in Mauritius (a “secondary dividend”) of which it owns either directly or indirectly at least 5% of the share capital, such dividend will be allowable as a foreign tax credit and an underlying foreign tax credit will also be available.
  • Mauritius has no thin capitalisation rules.
  • Interest and royalty payments paid by Global Business Licence companies are fully tax deductible in Mauritius.
  • Tax sparing credits are available – Under this regime the effective rate of taxation in Mauritius can be reduced as a long stop provision exists whereby Global Business Licence companies may elect not to provide written evidence to the Commissioner showing the amount of foreign tax charged and enjoy deemed taxation at 80% of the normal rate of 15%, i.e. 12%. Thus, use of this long stop provision in isolation would reduce the effective rate of taxation in Mauritius from 15% to 3%.
Double Taxation

Double Taxation Agreements
Mauritius has an extensive double tax treaty network which includes treaties with the following countries: Australia (Partial), Barbados, Belgium, Botswana, Cabo Verde, Congo, Croatia, Cyprus, Egypt, France, Germany, Guernsey, India, Italy, Kuwait, Lesotho, Luxembourg, Madagascar, Malaysia,
Malta, Monaco, Mozambique, Namibia, Nepal, Oman, Pakistan, People’s Republic of Bangladesh, People’s Republic of China, Rwanda, Senegal, Seychelles, Singapore, Sri Lanka, South Africa, State of Qatar, Swaziland, Sweden, Thailand, Tunisia, Uganda, United Arab Emirates, United Kingdom, Zambia and Zimbabwe.

Double Tax Avoidance Treaties
Mauritius has focused the development of its Global Business centre on the use of its growing network of double taxation treaties for structuring investment abroad. So far Mauritius has ratified over forty treaties and is party to a series of treaties under negotiation. The treaties currently in force are with Barbados, Belgium, Botswania, Croatia, Cyprus, France, Germany, India, Italy, Kuwait, Lesotho, Luxembourg, Madagascar, Malaysia, Mozambique, Namibia, Nepal, Oman, Pakistan, People’s Republic of China, Rwanda, Senegal, Seychelles, Singapore, South Africa, Sri Lanka, Swaziland, Sweden, Thailand, Uganda, United Arab Emirates, United Kingdom and Zimbabwe.

Eligible Entities of Double Taxation avoidance Treaties
Tax treaty benefits are only available to resident entities or persons. Accordingly, a resident entity must be liable to tax in Mauritius under its laws by reason of its domicile, residence or criterion of a similar nature. Mauritius provides a wide range of resident entities and hybrid structures including the Global Business Company, the Trust and the Société. A foreign company including the Global Business Company may benefit from the tax treaty network. It is also possible for Mauritian branch of a foreign company to access the tax treaties by satisfying the conditions of residence. These entities if wishing to avail of the benefits of a tax treaty must obtain a Tax Residence Certificate issued by the Mauritius Revenue Authority.

Scope of Double Taxation avoidance Treaties
All Mauritian double taxation avoidance treaties are based on the OECD Model Treaty of 1977. Under the post-independence treaties concluded so far, tax sparing is available. This implies that where Mauritian source dividends are exempt from tax under the tax incentive provisions, the foreign investor is entitled to credit a notional amount of Mauritian tax against the tax payable (if any) in his country, thus reducing his domestic tax liability.

Unilateral Relief
If a resident of Mauritius derives income from a foreign country that has not concluded a tax treaty with Mauritius and foreign income tax is paid on the income, that tax may be credited against Mauritian income tax. The credit is limited on a source-by-source basis to the lesser of the foreign tax paid on the income concerned and the Mauritian income tax payable on the same income. In the case of foreign source dividends, no credit relief if granted for foreign corporate income tax borne on the profits out of which the dividends are paid (underlying tax).

Taxation of Expatriates on Work Permit

Expatriates employed in Mauritius are subject to the same regulations as local taxpayers and are assessed for income tax on income earned in Mauritius. Certain allowances and deductions cannot be claimed by expatriates in an income year during which they are not considered to be residents of Mauritius.

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OCRA Worldwide announces strategic merger with Acclime

17th November 2022, Hong Kong - OCRA Worldwide (OCRA), announces today that it has completed the strategic merger with Asia Pacific’s premier corporate services provider Acclime (www.acclime.com). This is the latest step in Acclime’s active expansion as the Asia specialist in compliance and corporate services throughout the region.

Established in 1975 and led by Bart Dekker and Dharmesh Naik, OCRA is one of the industry pioneers in the corporate services sector with a full suite of corporate services from company formation, company secretarial support, accounting, and HR services. Over the past 40 years, OCRA has become a truly global business by providing very personalised services to their clients, most of whom are private investors or companies investing abroad.

From its founding base in Europe, OCRA has morphed over the past decade to focus on the faster growing markets of Asia and the Indian Ocean, and currently has teams in Hong Kong, Shanghai, Singapore, Mauritius and the Seychelles with around 80 staff. Additionally, OCRA is licensed in Samoa and the UAE to provide incorporation services to clients and referral partners.

"The high quality of the team, the interesting gateway jurisdictions of Mauritius and UAE which are important investment hubs for Africa and India, and the synergy of offering OCRA clients more services and Asian locations for expanding their business were the strategic logic for Acclime's interest in acquiring OCRA," said Martin Crawford, CEO and Co-Founder of Acclime. "We look forward to introducing OCRA’s corporate clients to our regional experts in China, Hong Kong, Australia, Cambodia, Indonesia, Malaysia, Thailand, India, Philippines, Singapore and Vietnam," he added.

The sale of the business was managed by the corporate advisory team of Mazars in London (Paul Joyce & Fred Dearden), acting for the ultimate shareholder of OCRA, and was opened for bids. "Acclime was chosen as the preferred bidder as the team recognised the cultural similarities, with high quality, personalised services at the core," said Bart Dekker, OCRA’s Managing Director, Asia Pacific. Dharmesh Naik, OCRA's Managing Director, Middle East and Indian Ocean, added, "We are excited and delighted to become an integral part of a large international team with the established resources across Acclime's network, and to execute the transaction in line with OCRA's long term succession plan in the interest of all of our stakeholders."

OCRA will operate as an independent business unit within Acclime, supported by funding, IT and marketing initiatives that will grow the business further. Bart Dekker and Dharmesh Naik will remain running the business post-acquisition.

The transaction is subjected to regulatory approvals in several locations and Acclime is expected to complete the acquisition by the end of 2022.

About OCRA
Established in 1975, OCRA is one of the industry pioneers in the corporate services sector with a full suite of corporate services from company formation, company secretarial support, accounting and HR services. For over 40 years, OCRA has been providing personalised services to its clients, most of whom are private investors or companies investing abroad.

About Acclime
Acclime, the premier corporate services provider in Asia, helps corporate and private clients to advance their businesses and interests in difficult-to-navigate markets in emerging Asia. The company’s vision is to reinvent the corporate services sector with innovative solutions that are seamlessly delivered to the highest global standards.

Enquiries: enquiries@ocra.com