The Finance Act 2025, which provides for a number of important tax changes announced in the Mauritian National Budget by Prime Minister and Minister of Finance Dr Navinchandra Ramgoolam in June, was gazetted on 9 August after receiving Presidential assent.
In line with OECD’s Global Anti-Base Erosion rules under Pillar Two, the Qualified Domestic Minimum Top-Up-Tax (QDMTT) will apply to all financial years ending after 31 December 2024. Introduced in 2022, it applies only to large multinational enterprises with annual turnover exceeding €750 million.
An Alternative Minimum Tax of 10% applicable on adjusted book profits is introduced for certain sectors including hotels, insurance, real estate, telecoms and financial intermediation. AMT is not applicable to Global Business entities, exempt companies and companies benefitting from a tax holiday, irrespective of whether they have accumulated tax losses or not.
The new Fair Share Contribution (FSC) at a rate of 15% is introduced for both individuals and entities for the period 1 July 2025 to 30 June 2028. The Finance Act clarifies that only income above MUR12 million (c. USD265,000), inclusive of local dividends, will be subject to the FSC for individuals. For the purpose of computing FSC for individuals, dividends from Trusts and Foundations will be excluded.
For companies, the FSC applies only to entities with chargeable income above MUR 24 million, but it then applies to the entire amount, at the following rates:
- 5% of chargeable income for companies taxed at the standard 15% rate.
- 2% for companies enjoying a reduced tax rate.
- 5% on banks’ income, including transactions with non-residents and holders of a Global Business Licence (GBL).
- An additional 2.5% on banks’ domestic income only.
Companies holding a Global Business Corporation (GBC) license or enjoying tax holidays are excluded, and no foreign tax credits can be utilised to offset liability to the FSC.
The 80% Partial Exemption Regime (PER) will be extended to income derived by Virtual Asset Service Providers engaged in exchange, transfer, safekeeping and administration of virtual assets, subject to meeting the prescribed substance requirements, for years of assessment commencing from 1 July 2026. The PER in respect of dividends will not be available to banks and in respect of interest income will only be available if the relevant activity of the company generating the interest income satisfies the conditions relating to substance requirements.
The rate of Registration Duty and Land Transfer Tax (LTT) applicable of on the purchase (by non-citizens) or sale of properties under Economic Development Board (EDB) property schemes – Smart City Scheme, Property Development Scheme, Real Estate Scheme and the Invest Hotel Scheme – and other approved schemes are to be raised from 5% to 10% from 1 July 2026.
Tax incentives available to Smart City companies and developers, such as eight-year income tax holidays and exemption from registration duty or land transfer tax, have been grandfathered where a letter of comfort was issued before 5 June 2025. After this date, tax incentives will be restricted to projects relating to public roads or transport.
The 35% tax rate cap for banks will only apply to transactions with residents other than global business entities.
The minimum monthly basic salary requirement for obtaining the Professional Occupational Permit has been raised from MUR22,500 to MUR30,000.
“The Finance Act 2025 is a clear balance of priorities, perhaps overly ambitious however. Pressures to raise revenue, meet international tax obligations, while preserving competitiveness and not undermining investor confidence is a grand ask”, says Richard Neal, Commercial Director – Africa for the Sovereign Group. “The clear and present risk is that the attempts to manage internal fiscal and global tax harmonisation pressures will be at the cost of foreign investor’s sentiment”. “This said, if Mauritius is able to execute the regulatory roll-out with clarity, fairness and monitors the impacts dynamically, the Financial Act 2025 could mark a turning point in the country’s fiscal maturity”.
