Mauritius brings in a 15% domestic minimum top-up tax for large groups
Mauritius's Finance Act 2025 adds a qualified domestic minimum top-up tax to the Income Tax Act 1995 from the year of assessment starting 1 July 2025. Mauritian entities of multinational groups with revenue of at least EUR 750 million pay top-up tax where their combined effective rate in Mauritius is below 15%. Detailed regulations followed in July 2026.
The Finance Act 2025 inserted a new Sub-Part AF (sections 50P to 50Z) into Part IV of the Income Tax Act 1995.
What changed
- A qualified domestic minimum top-up tax applies to Mauritian entities of multinational groups with consolidated revenue of at least EUR 750 million in two of the four preceding years.
- Where the group's Mauritian entities have a combined effective tax rate below 15%, they pay top-up tax in Mauritius to bring it to 15%.
- It applies from the year of assessment beginning 1 July 2025.
- Mauritius has not adopted the income inclusion rule or the undertaxed profits rule.
- Government entities, international organisations, non-profits, pension funds and investment funds are excluded.
Later developments
The Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026, made on 28 July 2026 and gazetted on 8 August 2026, set out the detailed rules and apply from 1 July 2025.
Who is affected
Mauritian companies in large multinational groups, including Global Business Companies, and their tax teams.