Mauritius | Kenya | Seychelles
 
 
Axis specializes in developing trust
structures that protect your assets.
As part of its regional expansion, Axis has now established a presence in Seychelles and Kenya.
Axis can set up and manage tax-incentive companies and offshore entities in Mauritius.
Mauritius has recently opened up its
real-estate market to foreigners.
Axis provides specialist offshore fund
services for a full range of fund structures.
Axis further consolidates its preferred relationship with BLC Robert by becoming an affiliate of ALN.
 
Mauritius
Taxation

The Taxation System In Mauritius


Mauritius runs a self-assessment system based on the residence concept. A person resident in Mauritius is liable to tax on the worldwide income derived by that person.

A non-resident is taxed on income derived from sources in Mauritius.

However, all income derived from overseas by an individual resident in Mauritius is taxable to the extent it is remitted to Mauritius.

Income tax is payable on income derived in the preceding year . The fiscal year runs from 1 January to 31 December.

There is no capital gains tax in Mauritius.

Fiscal Regime


(A) Domestic Companies


The tax rates on the chargeable income of domestic companies is 15%.

(B) Companies Holding Category 1 Global Business Licence-gbc1 Including Funds.


GBC1 is taxed on its chargeable income (including dividends, interests and other income but not capital gains less expenses) at a corporate rate of 15% which is reduced to a net effective tax rate of 3% or even less. This can be elaborated as follows:

    Net Rate %
Normal tax rate 15%  
Less (12%) 3
EITHER    
Deemed tax credit of 80% on foreign sourced income    
– 80% of 15%    
OR    
Actual foreign tax credit, if written evidence is available    
where then the tax payment in Mauritius can even be (Actual foreign tax credit) 0-3


Foreign Tax Credit

If there is written evidence of foreign tax paid, the GBC1 can claim the higher of the deemed tax credit of 80% or the foreign tax credit against Mauritian tax for actual:

  • withholding taxes suffered abroad on income remitted to Mauritius;
  • foreign corporation tax charged on income out of which dividend is paid (i.e the underlying tax credit) if the GBC1 holds not less than 5% of the share capital of the company paying the dividend.


In the absence of evidence, the amount of foreign tax shall nevertheless be conclusively presumed to be 80% of the Mauritian tax chargeable with respect to that income.

General Features applicable to GBC1

  • All payments by a GBC1 whether by way of dividends, interest or royalties are not subject to any Mauritian withholding tax or levy.
  • A GBC1 is exempted from payment of any Mauritian registration, capital, stamp or other duty or similar charges
  • Non-resident shareholders are not subject to any tax or other liability as holder or beneficial owner of shares in a GBC1.
  • No estate duty or inheritance tax is payable on the inheritance of shares in a GBC1

(C) Companies Holding Category 2 Global Business Licence- Gbc2


A GBC2 is not considered to be resident in Mauritius and is not liable to tax. As a non-resident of Mauritius, such a company is not covered by any Double Taxation Agreement concluded by Mauritius.

No estate duty or inheritance tax is payable on the inheritance of shares in a GBC2.

A GBC2 is also exempted from payment of any Mauritian registration, capital, stamp or other duty or similar charges

(D) Trusts


Non resident Trusts are tax exempt.

Resident Trusts are taxable at a rate of 15% and they can apply for a GBC1 licence. The same provisions as for a GBC1 as mentioned above will apply.

(E) Resident Societe


A resident Société with a GBC1 licence is not subject to tax. However, every associate of the société is liable to income tax in respect of his share of income in that société.