Mauritius: local rules

Mauritius has an arm's length rule in section 75 of the Income Tax Act 1995. It lets the Director-General adjust the income of a business that deals with a connected person on terms that are not arm's length. The Finance Act 2025 (gazetted 9 August 2025) added subsection (2A), which requires a company in a transaction covered by section 75(1) to prepare and keep transfer pricing records "as may be prescribed", and subsection (4), which defines "connected persons" and "transaction". EY reports both took effect on 8 August 2025. In October 2026 no transfer pricing regulations had been found, so the form of the records is not yet set. The OECD guidelines are the expected standard but no official page was found that says so.

There is no master file or local file rule yet. Section 75(2A) sets the duty to keep records, and the details are left to regulations that were not found in October 2026. Commentators expect OECD style documentation (functional analysis, method choice, benchmarking) kept ready for the MRA on request, but that is expectation, not law. No response period, thresholds or filing date exist. Separately, groups with consolidated revenue of EUR 750 million or more file a country-by-country report and notification (Income Tax (Country-by-Country Reporting) Regulations 2018, GN 20/2018).

No methods are listed in Mauritian law. Section 75 only asks for an arm's length result. The standard OECD methods are what advisers expect, and the Finance Act 2025 change is described as bringing Mauritius closer to the OECD guidelines. Safe harbours may come with the regulations but none exist today.

There is no transfer pricing penalty yet. An adjustment under section 75 brings the usual tax, penalty and interest. For returns, the MRA outline (from 2016, so check current rates) gives Rs 2,000 for each month or part month of a late annual return up to Rs 20,000, 5% of unpaid tax for late payment, and interest of 0.5% a month. CbC failures can be fined Rs 5,000, then Rs 10,000 a month up to Rs 120,000, and inaccurate information up to Rs 50,000 (regulation 7A). Late top-up tax costs 2.5% of the tax plus interest of 0.25% a month.

Mauritius has a Qualified Domestic Minimum Top-up Tax (QDMTT, also called the DMTT) and no income inclusion rule or undertaxed profits rule. It sits in Sub-Part AF (sections 50P to 50Z) of the Income Tax Act, added by the Finance Act 2025, and applies from the year of assessment starting 1 July 2025, which covers fiscal years ending on or after 1 January 2025. The detailed Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026 (GN 135 of 2026) were made on 28 July 2026 and gazetted on 8 August 2026, deemed in force from 1 July 2025. The group threshold is EUR 750 million in at least 2 of the 4 prior years. Two filings: a notification of the Mauritian filing company within 6 months after the group's fiscal year end, and the DMTT return with payment within 15 months after the end of the month in which the fiscal year ends. Mauritius has no IIR or UTPR and no separate GloBE Information Return filing was found; the DMTT return is filed in XML on the MRA e-services platform. For fiscal years ending 1 January to 31 May 2025, the first returns were due 7 September 2026, extended by the MRA to 30 September 2026.

The company return is due 6 months after the end of the month in which the accounting year ends (section 116). For 31 December and 30 June year ends, and for APS statements due in June or December, the MRA sets the date 2 days, excluding Saturdays and public holidays, before the month end, so check the MRA communique each period. Under the Interpretation and General Clauses Act s 38, a deadline that falls on a Saturday, Sunday or public holiday moves to the next day that is not a public holiday.