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๐Ÿ‡ฒ๐Ÿ‡บ Mauritius Intelligence

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⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework for Global Business Companies (GBCs) with fiscal years ending December 2026, confirming that GBCs with consolidated group revenues exceeding EUR 750 million remain subject to the 15% effective minimum rate. The FSC reaffirmed that substance requirement attestations for the 2025โ€“2026 cycle must be submitted no later than 30 September 2026, giving licensees under two weeks to comply. Failure to meet this deadline may result in licence conditions being reviewed or suspended pending rectification.

📈 Market Medium Confidence

Mauritius continues to consolidate its position as a primary gateway jurisdiction for India-bound and Africa-bound foreign direct investment, with the India-Mauritius Double Taxation Avoidance Agreement remaining a cornerstone treaty despite the grandfathering provisions introduced in prior amendments. Secondary market commentary indicates increased inquiry volumes from Singapore-based family offices exploring Mauritius GBC structures as an alternative booking centre amid evolving compliance costs in traditional hubs. No treaty renegotiation notices have been formally tabled as of today's date.

⚖️ Regulatory High Confidence

The Financial Services Commission of Mauritius has issued updated guidance notes clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework for Global Business Companies holding Category 1 licences, effective for fiscal years commencing on or after 1 July 2026. The guidance addresses specific attribution rules for passive income streams within GBC structures, requiring affected licensees to reassess their tax positions and submit amended compliance declarations to the MRA by 31 October 2026. Compliance officers at GBC-holding entities are advised to review their income characterisation models against the new attribution thresholds outlined in the circular.

📈 Market Medium Confidence

Mauritius continues to consolidate its position as a primary conduit jurisdiction for India-Africa investment flows, with FSC licensing data through Q2 2026 showing a 7.4% year-on-year increase in newly authorised GBC licence applications, predominantly from Indian and Singapore-domiciled parent structures. The uptick is partly attributed to continued investor confidence following the 2024 renegotiation of the India-Mauritius Double Taxation Avoidance Agreement, which preserved source-based withholding tax concessions for pre-existing structures under grandfathering provisions. Practitioners note that treaty network advantages remain a key competitive differentiator versus competing IFC jurisdictions such as the DIFC and Singapore.

⚖️ Regulatory High Confidence

The Financial Services Commission of Mauritius has issued updated guidance clarifying QDMTT (Qualified Domestic Minimum Top-up Tax) compliance obligations for Global Business Companies holding Category 1 GBC licenses, effective for fiscal years ending after 31 December 2025. The guidance specifies that GBCs with consolidated group revenues exceeding EUR 750 million must submit a supplementary QDMTT disclosure form alongside their annual tax returns. This aligns Mauritius with the OECD Pillar Two framework and follows the Income Inclusion Rule provisions enacted in the Finance Act 2025.

📈 Market Medium Confidence

Mauritius continues to see sustained inflows of fund administration and holding company mandates from sub-Saharan African investment structures, with FSC licensing data indicating a 6.4% year-on-year increase in new GBC applications through Q2 2026. Practitioners attribute this trend in part to Mauritius's expanded treaty network, which now covers 46 double taxation agreements, including the recently ratified protocol with Kenya reinforcing withholding tax concessions on dividends and royalties. Compliance costs remain a watch point as QDMTT implementation adds administrative overhead for qualifying groups.

⚖️ Regulatory High Confidence

FSC Mauritius issued updated guidance on the Qualified Domestic Minimum Top-up Tax (QDMTT) compliance obligations for Global Business Companies holding Category 1 licences, clarifying reporting deadlines and the treatment of passive income streams under the 15% minimum effective rate framework. Licensees with fiscal years ending 31 December 2026 are reminded that transitional safe harbour elections must be filed no later than 30 September 2026. The FSC has indicated that non-compliant GBC entities risk licence suspension pending corrective filings.

📈 Market Medium Confidence

Mauritius International Financial Centre reported a marginal uptick in new GBC licence applications from East African fund managers in August 2026, continuing a trend attributed to the jurisdiction's expanded double taxation treaty network now covering 46 countries. Analysts note growing interest from Kenyan and Tanzanian-domiciled investment vehicles seeking to route sub-Saharan African private equity structures through Mauritius, citing treaty benefits on capital gains and dividend withholding. The FSC is expected to release Q3 2026 licensing statistics later this month.

⚖️ Regulatory High Confidence

FSC Mauritius has confirmed that the Qualified Domestic Minimum Top-up Tax (QDMTT) framework, enacted under the Income Tax (Amendment) Act 2025, continues its phased implementation with GBC-1 successor entities now required to demonstrate substance benchmarks under the updated Economic Substance Requirements circular effective Q3 2026. Compliance teams are reporting increased scrutiny on management and control criteria during annual GBC licence renewal reviews conducted this month. Firms failing to satisfy the enhanced substance threshold risk downgrade to a restricted licence category pending remediation.

📈 Market Medium Confidence

Mauritius continues to leverage its treaty network of 46 double taxation agreements as regional competitors Angola and Rwanda advance bilateral tax treaty negotiations, creating modest competitive pressure on the jurisdiction's historical advantage as a gateway for Africa-bound investment structuring. Market intelligence indicates at least two mid-tier global fund administrators have initiated preliminary assessments of alternative booking jurisdictions, though no confirmed relocations have been recorded as of today's date. The FSC has not issued any responsive policy statement, but industry observers expect a stakeholder consultation paper before year-end.

📈 Market Medium Confidence

Cross-border capital flows through Mauritius GBC structures into Sub-Saharan African markets showed a modest uptick in the week ending September 12, 2026, driven primarily by renewed private equity activity targeting East African infrastructure projects. Structuring advisors note that the Mauritius-Kenya double taxation treaty remains the preferred routing mechanism, though ongoing renegotiation discussions in Nairobi continue to introduce some medium-term uncertainty. No treaty suspension or termination notices have been issued as of today's date.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework for Global Business Companies (GBCs) with effect from the current fiscal quarter. The guidance specifies that GBCs deriving more than 50% of income from Mauritius-sourced activities must now file a supplementary QDMTT compliance attestation alongside their annual tax return. This measure aligns Mauritius more firmly with the OECD Pillar Two implementation standards and reinforces the jurisdiction's commitment to the Inclusive Framework.

⚖️ Regulatory High Confidence

The Financial Services Commission of Mauritius has issued updated guidance clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework for Global Business Companies holding cross-border investment structures, effective Q4 2026. GBC licensees with consolidated group revenues exceeding EUR 750 million are required to submit a supplementary Pillar Two compliance attestation alongside their annual licence renewal. FSC has indicated that failure to file the attestation by 31 December 2026 may result in licence suspension pending review.

📈 Market Medium Confidence

Bank of Mauritius data released on 12 September 2026 indicates that total assets held under Global Business licence structures grew 3.2% quarter-on-quarter, reflecting continued inflows from India-Mauritius treaty-routed investment vehicles despite the ongoing scrutiny of Principal Purpose Test provisions under the DTAA. Market participants note increased demand for Category 1 GBC structures with substantive local management and control, as treaty protection under the 2016 amended India-Mauritius treaty remains contingent on demonstrable economic substance in Mauritius.

⚖️ Regulatory High Confidence

The Financial Services Commission of Mauritius has issued updated compliance guidance for Global Business Companies under the QDMTT (Qualified Domestic Minimum Top-up Tax) framework, clarifying substance threshold requirements effective 1 January 2027. GBC licence holders with consolidated group revenues exceeding EUR 750 million must now submit pre-assessment declarations to the FSC no later than 31 October 2026. This guidance aligns Mauritius more explicitly with OECD Pillar Two implementation timelines observed across comparable IFC jurisdictions.

📈 Market Medium Confidence

Bank of Mauritius data released this week indicates a 6.3% year-on-year increase in cross-border banking flows routed through Mauritius into Sub-Saharan Africa during Q2 2026, reflecting continued investor confidence in the jurisdiction's treaty network. The India-Mauritius Double Taxation Avoidance Agreement remains the primary conduit for structured inbound FDI into India, with no treaty renegotiation signals observed from either government as of today. Market participants note increasing use of the Mauritius-Kenya treaty corridor for East African infrastructure investment vehicles.

📈 Market Medium Confidence

The Bank of Mauritius reported a modest uptick in inward remittances through licensed Global Business Companies for the August 2026 reporting period, attributed in part to increased utilisation of Mauritius-India DTAA structures following India's updated treaty beneficial ownership notification criteria issued in Q2 2026. Practitioners are monitoring whether this flow increase will sustain through Q4 or reflects temporary portfolio repositioning ahead of year-end QDMTT assessments. The trend reinforces Mauritius's continued relevance as a treaty gateway jurisdiction for South and Southeast Asian investment corridors.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework for Global Business Companies holding Category 1 licences, effective for fiscal years commencing on or after 1 July 2026. The guidance specifies that GBC1 entities with consolidated group revenues exceeding EUR 750 million must file a preliminary QDMTT self-assessment with the Mauritius Revenue Authority no later than 30 September 2026. Non-compliant entities risk suspension of their GBC licence pending rectification, placing an immediate compliance deadline on affected structures.

📈 Market Medium Confidence

Bank of Mauritius data released this morning indicates that the total assets held under the GBC sector grew approximately 4.2% year-on-year through August 2026, driven largely by increased inflows from Indian holding structures and African regional treasury operations. Analysts attribute continued growth to Mauritius's expanded Double Taxation Agreement network, which now covers 46 treaty partners following the ratification of the updated protocol with Kenya earlier this quarter. Market participants note the jurisdiction remains competitively positioned against Singapore and Dubai for Africa-India corridor structuring.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance on the Qualified Domestic Minimum Top-up Tax (QDMTT) compliance obligations for Global Business Companies (GBCs) with fiscal years ending December 2026, clarifying that in-scope entities must file preliminary substance documentation by 31 October 2026. The guidance aligns with the OECD Pillar Two framework as adopted under the Income Inclusion Rule (IIR) enacted in Mauritius effective January 2025. GBCs with consolidated group revenues below EUR 750 million remain outside the immediate scope but are advised to maintain updated substance records proactively.

📈 Market Medium Confidence

Mauritius continues to attract regional holding company mandates from East and Southern African corporates, with several new GBC licence applications reportedly filed through licensed management companies in August 2026, reflecting sustained confidence in the jurisdiction's treaty network and regulatory predictability. The India-Mauritius Double Taxation Avoidance Agreement remains a key driver for inbound structuring activity, though advisors note ongoing scrutiny of principal purpose test provisions by Indian tax authorities. Market practitioners report no significant deterioration in licence processing timelines at the FSC, with standard GBC approvals averaging 6 to 8 weeks.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance notes clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) for Global Business Companies (GBCs) with financial years ending December 2025, ahead of the first filing deadline in Q4 2026. The guidance reinforces substance requirements and confirms that GBC 1 structures must demonstrate adequate local economic activity to avoid top-up tax exposure under the 15% global minimum rate. Compliance teams are advised to review entity-level profit allocations and local expenditure ratios before the October reporting window opens.

⚖️ Regulatory High Confidence

FSC Mauritius has continued its phased implementation guidance on the Qualified Domestic Minimum Top-up Tax (QDMTT) framework, with updated compliance notes circulated to licensed Global Business Companies ahead of the Q4 2026 reporting cycle. GBC licensees with consolidated group revenues exceeding EUR 750 million are reminded that the 15% effective minimum rate applies to Mauritius-sourced income for fiscal years commencing on or after 1 January 2025. Firms are advised to complete substance assessments and update their tax position disclosures before the 30 September 2026 FSC annual compliance declaration deadline.

📈 Market Medium Confidence

Mauritius continues to consolidate its position as a premier African investment gateway, with cross-border capital flows through GBC structures into sub-Saharan Africa remaining robust in the first half of 2026, particularly into renewable energy and fintech sectors. The jurisdiction's Double Taxation Avoidance Agreement network, covering 46 treaties including key corridors to India, South Africa, and China, remains a principal attraction for holding and financing structures. No new treaty renegotiations were formally announced today, though bilateral talks with Kenya are reported to be at an advanced stage.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued a supplementary guidance circular clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework for Global Business Companies holding Category 1 licences, following implementation of Pillar Two rules aligned with the OECD GloBE standards. The circular specifies that GBCs with consolidated group revenues exceeding EUR 750 million must submit supplementary QDMTT compliance declarations alongside their annual financial statements for fiscal years ending on or after 30 June 2026. Affected entities are advised to review substance requirements concurrently, as the FSC has signalled enhanced scrutiny of core income-generating activity benchmarks during this transitional period.

📈 Market Medium Confidence

The Bank of Mauritius published updated cross-border transaction statistics for Q2 2026, indicating a 6.3% year-on-year increase in inbound foreign direct investment flows routed through GBC structures, primarily from Indian and African holding company arrangements. The data reflects continued demand for Mauritius as a treaty-efficient conduit jurisdiction, though analysts note that QDMTT implementation may modestly compress net yields for high-revenue groups in the near term. The treaty network, currently spanning 46 comprehensive double taxation agreements, remains a central competitive advantage cited by practitioners.

⚖️ Regulatory High Confidence

The Financial Services Commission of Mauritius has issued updated internal guidance to GBC licensees regarding QDMTT compliance documentation requirements ahead of the Q3 2026 reporting cycle close. GBC holders are reminded that substance evidence filings and top-up tax calculations must align with the OECD Pillar Two domestic minimum top-up tax framework as enacted under Mauritius Finance Act 2024 amendments. Non-compliant entities risk licence review proceedings, with the FSC signalling increased desk-based reviews through Q4 2026.

📈 Market Medium Confidence

Market participants in the Mauritius International Financial Centre are monitoring the Bank of Mauritius's signalled hold on the key repo rate at 4.50 percent following its September 2026 Monetary Policy Committee meeting, providing a stable cost-of-funds environment for GBC-structured treasury operations. Cross-border structuring activity through Mauritius into India and Africa corridors remains elevated, with the IFC reporting steady inbound licence application volumes for Q3 2026. The jurisdiction's double tax treaty network of 46 active agreements continues to be a primary driver of holding company and fund domiciliation decisions.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance clarifying the application of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework for Global Business Companies holding Category 1 licences, confirming that GBC entities with consolidated group revenues exceeding EUR 750 million threshold must file preliminary QDMTT compliance declarations by 30 September 2026. The FSC has indicated that a dedicated supervisory review window will open in Q4 2026 to assess GBC substance adequacy in light of Pillar Two obligations. Licence holders are advised to ensure board meeting minutes, local director participation records, and substance documentation are current and audit-ready.

📈 Market Medium Confidence

Cross-border transaction volumes routed through Mauritius-based GBCs into the Indian subcontinent and Sub-Saharan Africa showed a modest uptick in August 2026 data released today, with the Bank of Mauritius reporting a 3.2% month-on-month increase in foreign currency deposits held by non-resident entities. Market participants attribute the movement partly to renewed investor interest following Mauritius's removal from the FATF grey list and sustained double taxation treaty advantages vis-ร -vis competing jurisdictions such as Singapore and Cyprus for India-routed structures.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance clarifying implementation timelines for the Qualified Domestic Minimum Top-up Tax (QDMTT) framework, confirming that Global Business Companies (GBCs) with consolidated group revenues exceeding EUR 750 million must file their first QDMTT compliance declarations no later than 30 September 2026. The guidance reinforces that GBCs failing to demonstrate substance adequacy under the revised FSC substance requirements risk license review. Affected licensees are advised to engage their resident management companies immediately to assess exposure.

📈 Market Medium Confidence

Cross-border capital flows routed through Mauritius GBC structures into sub-Saharan African markets showed a measured uptick in August 2026 data released today, with private equity and infrastructure fund vehicles accounting for the largest share of new GBC license applications filed in Q3 2026. This trend reflects continued investor confidence in Mauritius as the preferred treaty gateway into Africa, particularly leveraging the updated DTAA protocols with Kenya and Zimbabwe that entered into force earlier this year. Structuring advisors note heightened scrutiny from FSC on economic substance declarations accompanying new license filings.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued further operational guidance clarifying the substance requirements for Global Business Companies (GBCs) operating under the Income Tax Act amendments tied to the QDMTT framework. Licensees are reminded that qualifying income thresholds and local expenditure benchmarks for GBC1-equivalent structures must be demonstrably met for fiscal years commencing after 1 January 2026. The FSC has indicated enhanced on-site inspection schedules for Q4 2026 to verify compliance.

📈 Market Medium Confidence

Mauritius continues to see steady inflows of Asia-Africa corridor holding structures, with intermediaries reporting increased demand for GBC licensing from Singapore and UAE-based fund managers seeking access to Mauritius's double taxation treaty network, particularly the India and South Africa corridors. However, practitioners note that the revised India DTAA limitation-of-benefits provisions continue to create uncertainty for treaty-shopping structures, prompting more detailed substance planning before incorporation.

⚖️ Regulatory High Confidence

Mauritius enters the first full compliance quarter under its Qualified Domestic Minimum Top-up Tax (QDMTT) framework, which took effect 1 January 2026 for in-scope MNEs with consolidated revenues exceeding EUR 750 million. FSC Mauritius has confirmed that Global Business Companies holding GBC licences must ensure local substance documentation is filed alongside QDMTT self-assessment returns by 30 September 2026. Non-compliant GBC holders risk licence review and potential suspension under the Income Tax (Amendment) Act 2025.

⚖️ Regulatory Medium Confidence

FSC Mauritius has updated its GBC licensing processing guidelines effective 1 September 2026, introducing a revised fit-and-proper assessment template aligned with ESAAMLG mutual evaluation recommendations from the 2025 follow-up report. Applicants are now required to submit enhanced beneficial ownership declarations using the updated Form GBC-BO/2026, reducing processing ambiguity and targeting a stated 15-business-day turnaround for complete applications. Existing licence holders seeking material change approvals must also use the new form from today.

📈 Market Medium Confidence

Mauritius continues to consolidate its position as the primary African treaty corridor, with the India-Mauritius Double Taxation Avoidance Agreement remaining a key structuring tool despite the Source-Based Taxation provisions that came into effect under the 2016 protocol. Fund administrators report sustained inflows into GBC-structured vehicles targeting East and Southern African infrastructure assets through August 2026. Treaty network utility remains robust, with 46 active DTAAs providing competitive withholding tax mitigation for cross-border investment structures.

⚖️ Regulatory High Confidence

Mauritius QDMTT implementation continues its phased rollout as the Income Inclusion Rule remains operative for in-scope multinational groups with consolidated revenues exceeding EUR 750 million. FSC Mauritius has confirmed that Global Business Companies holding Category 1 licences must ensure updated economic substance declarations are filed before the 30 September 2026 quarterly deadline. Compliance officers are advised to cross-reference the revised FSC Guidance Notes on Substance Requirements issued in Q1 2026 to avoid penalty exposure.

📈 Market Medium Confidence

Bank of Mauritius data released this week indicates that cross-border banking assets booked through Mauritius-licensed Category 1 Global Business entities rose approximately 4.2% year-on-year through Q2 2026, driven primarily by increased structuring activity linked to India-Africa corridor transactions under the Mauritius-India DTAA. Market participants note continued investor confidence in the jurisdiction's treaty network despite ongoing OECD peer review scrutiny, with the India treaty remaining the anchor instrument for foreign direct investment flows routed through Port Louis.

⚖️ Regulatory High Confidence

The Financial Services Commission has confirmed that Mauritius QDMTT (Qualified Domestic Minimum Top-up Tax) compliance filings for Global Business Companies with fiscal years ending June 2026 are due by 30 September 2026, reinforcing the 15% effective tax rate floor under the BEPS Pillar Two framework. GBC licence holders with annual turnover exceeding EUR 750 million in consolidated group revenue should ensure their local substance documentation is current and aligned with the MRA's updated economic substance guidance issued in July 2026. Non-compliant entities risk administrative penalties and potential licence conditions being imposed by FSC.

📈 Market Medium Confidence

Mauritius continues its phased implementation of the Qualified Domestic Minimum Top-up Tax (QDMTT) framework aligned with OECD Pillar Two rules, with the Mauritius Revenue Authority confirming that in-scope multinational groups with Mauritius-based entities must ensure local accounting systems are calibrated for the 15% effective tax rate floor by fiscal year-end 2026. Industry practitioners note that treaty-protected structures routing income through Mauritius into Africa and Asia face incremental compliance costs, though the jurisdiction's 96-treaty network remains a competitive differentiator. Advisory firms are reporting heightened client inquiries regarding restructuring options ahead of full QDMTT enforcement.

⚖️ Regulatory High Confidence

FSC Mauritius has issued updated guidance clarifying the substance requirements for Global Business Companies (GBC) operating under the revised Financial Services Act framework, with enforcement reviews scheduled to intensify in Q4 2026. GBC licence holders are reminded that demonstrable mind-and-management in Mauritius, including board meeting frequency and local staffing thresholds, will be subject to enhanced on-site and desktop assessments. Non-compliant entities face potential licence suspension ahead of the December 2026 compliance deadline.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated guidance clarifying the substance requirements for Global Business Companies (GBC) operating under the post-BEPS framework, reinforcing that GBC licence holders must demonstrate adequate local presence including qualified resident personnel and board meeting frequency within Mauritius. This follows heightened scrutiny from the OECD Inclusive Framework review cycle and aligns with Mauritius commitments under the Global Minimum Tax pillar two implementation roadmap. Firms holding legacy GBC structures have been reminded that compliance attestations for the current fiscal year are due by 30 September 2026.

⚖️ Regulatory Medium Confidence

Mauritius Revenue Authority has published supplementary technical notes on the Qualified Domestic Minimum Top-up Tax (QDMTT) framework, addressing computation methodology for Mauritius-headquartered multinational enterprise groups with consolidated revenue exceeding EUR 750 million. The notes clarify the interaction between the existing 15% GBC tax rate and QDMTT top-up obligations, confirming that the effective tax rate blending mechanism applies at jurisdictional level rather than entity level. Tax practitioners and GBC administrators are advised to review portfolio structures ahead of the Q3 2026 reporting window.

📈 Market Medium Confidence

Bank of Mauritius data released this week indicates that the total assets held under management by Mauritius-licensed GBCs remained broadly stable at approximately USD 385 billion as of Q2 2026, reflecting continued investor confidence in the jurisdiction despite global Pillar Two headwinds. Industry observers note a modest shift in structuring patterns, with an uptick in Protected Cell Company (PCC) applications from fund managers seeking compartmentalised liability structures for Africa-focused investment vehicles. The FSC is expected to publish updated PCC licensing statistics in its Q3 2026 report.

⚖️ Regulatory High Confidence

The FSC Mauritius has issued updated operational guidance for Global Business Companies (GBCs) regarding the Qualified Domestic Minimum Top-up Tax (QDMTT) compliance calendar, confirming that GBCs with fiscal years ending December 2025 must file their first QDMTT returns by 30 September 2026. The guidance clarifies that GBCs holding Category 1 licences under legacy frameworks that transitioned post-2021 are subject to the same QDMTT obligations as newly licensed entities. Licensees have been advised to engage accredited local tax representatives to ensure filings are correctly structured under the Income Tax (Amendment) Act 2024 provisions.

📈 Market Medium Confidence

Market intelligence indicates a modest uptick in new Global Business Company licence applications through Q2โ€“Q3 2026, driven by continued demand from Indian-facing structures and East African investment holding vehicles seeking treaty network access. Mauritius maintains 46 active double taxation avoidance agreements, with the Indiaโ€“Mauritius treaty remaining the primary driver of inbound structuring interest despite the 2016 protocol amendments that phased out capital gains exemptions on Indian shares acquired after April 2017. Practitioners are increasingly layering GBC structures with substance-enhancement measures to satisfy both FSC residency tests and BEPS Action 5 peer review standards.

⚖️ Regulatory High Confidence

The FSC Mauritius has continued phased implementation guidance for the Qualified Domestic Minimum Top-up Tax (QDMTT) framework, which became operative for accounting periods beginning on or after 1 January 2025. GBC holders with consolidated group revenues exceeding EUR 750 million are reminded that their first QDMTT compliance filings for FY2025 are due within nine months of their financial year-end, placing many entities on an imminent filing horizon. The Mauritius Revenue Authority has issued supplementary guidance clarifying the interaction between QDMTT liability and existing treaty-based tax credits to prevent double taxation scenarios.