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4. Results: Answers
Corporate Tax
2.
Special regimes
2.1
What special regimes exist (eg, for fund entities, enterprise zones, free trade zones, investment in particular sectors such as oil and gas or other natural resources, shipping, insurance, securitisation, real estate or intellectual property)?
Mauritius

Answer ... Mauritius now provides for a partial exemption of up to 80% on certain streams of income, provided that the company satisfies certain substance requirements.

Income derived from several activities – such as aircraft leasing and acting as a collective investment scheme manager or investment manager – may benefit from the above exemption.

Several tax holidays currently exist with regard to innovation-driven activities and the manufacture of certain pharmaceutical products, among other things.

A special regime applies to banks.

The legislation also provides for certain tax-exempt vehicles (eg, special purpose funds).

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.2
Is relief available for corporate reorganisations or intra-group transfers of companies and other assets? Please include details of any participation regime.
Mauritius

Answer ... Yes – for example, losses may be carried forward for the following year only if at least 50% of the shares were held by or on behalf of the same person.

There is no tax on capital gains.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.3
Can a taxpayer elect for alternative taxation regimes (eg, different ways to calculate the taxable base, such as revenue-based versus profits based or cash basis versus accounts basis)?
Mauritius

Answer ... A small enterprise (which is prescriptively defined) may apply to the Mauritius Revenue Authority for the net income of its business to be computed on a cash basis instead of an accrual basis.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.4
What are the rules for taxing corporates with different functional or reporting currency from that of the jurisdiction in which they are resident?
Mauritius

Answer ... The Income Tax Act 1995 provides for income to be expressed in Mauritius rupees. However certain companies may prepare their financial statements in US dollars, euros, pounds sterling, Singapore dollars, South African rands, Swiss francs or such other foreign currency as may be approved by the Mauritius Revenue Authority, and pay their taxes in that amount.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.5
How are intangibles taxed?
Mauritius

Answer ... Where a taxpayer incurs capital expenditure on intangible assets which are used exclusively in the production of gross income of the taxpayer and are subject to depreciation under International Financial Reporting Standards, an annual allowance can be claimed on those intangible assets.

The chargeable income of a company which consists of income from intangible assets is taxed in the same way as other income (ie, at the headline rate of 15%).

However, effective from 1 July 2020, an eight-year tax exemption is available for companies set up on or after 1 July 2017 that meet the prescribed conditions and:

  • engage in innovation-driven activities involving IP assets which have been developed in Mauritius; or
  • derive income from IP assets which have been developed in Mauritius on or after 10 June 2019.

If the company does not satisfy the conditions for the eight-year tax exemption, any income derived on intangibles will be subject to tax in Mauritius.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.6
Are corporate-level deductions available for contributions to pensions?
Mauritius

Answer ... Contributions made by employers in respect of employees are deductible when calculating the company’s gross income, provided that the employer contributes to what is defined as a ‘superannuation fund’.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.7
Are taxpayers from different sectors (eg, banking) subject to different or additional taxes or surtaxes?
Mauritius

Answer ...

  • Banking: A special levy on banks is progressively applied to the income of banks.
  • Telecommunications service providers: A solidarity levy is applied to the book profits of telecommunications service providers.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.8
Are there other surtaxes (eg, solidarity surtax, education tax, corporate net wealth tax, remittance tax)?
Mauritius

Answer ... A solidarity tax is applied to individuals only.

Some companies are also liable to make contributions to the corporate social responsibility fund.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
2.9
Are there any deemed deductions against corporate tax for equity?
Mauritius

Answer ... Only interest incurred in the production of income is deductible. The Mauritius Revenue Authority has offered guidance that distributions made in relation to certain types of shares (normally preference shares which the shareholder can redeem at any point) may be treated as interest.

For more information about this answer please contact: Joe Chan from Andersen (Mauritius) Ltd
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Corporate Tax