1. Who this guide is for
This guide is for groups whose ultimate parent is located in Mauritius and their advisors. Mauritius holding companies within groups with an overseas ultimate parent can also fall within domestic top-up tax requirements.
Pillar Two generally covers multinational groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years, subject to special rules. Confirm the ultimate parent, consolidation perimeter and entity classifications before assessing exposure. The 15% minimum rate is tested using the applicable GloBE calculations, rather than the statutory corporate income tax rate alone.
2. Why parent location matters
Mauritius has introduced a domestic top-up tax under Sub-Part AF of Part IV of the Income Tax Act, supplemented by the 2026 Regulations. It addresses relevant low-taxed Mauritius profits.
The reviewed domestic framework does not establish a Mauritius IIR or UTPR. Overseas domestic top-up taxes, intermediate-parent IIR and foreign UTPR exposure therefore require separate assessment.
3. Questions about overseas operations
- Which Mauritius entities and income belong in the domestic calculation?
- How do partial exemptions, foreign tax credits and deferred taxes affect the result?
- Does the group’s fiscal year differ from local entities’ accounting periods, and which overseas jurisdictions collect domestic or residual top-up tax?
4. Local implementation information by rule and financial period
| Rule | Status | Applicable period | Source |
|---|---|---|---|
| QDMTTQualified Domestic Minimum Top-up Tax (QDMTT) | Enacted and operative | Fiscal years ending on or after 1 January 2025 | Income Tax Act — consolidated text |
| IIRIncome Inclusion Rule (IIR) | Implementation not established in the reviewed domestic framework | Commencement not established | No implementing instrument established in the source review |
| UTPRUndertaxed Profits Rule (UTPR) | Implementation not established in the reviewed domestic framework | Commencement not established | No implementing instrument established in the source review |
The table distinguishes domestic implementation from OECD qualification. Qualification and safe-harbour eligibility must be checked for the relevant rule and period. Absence from the OECD Central Record does not establish non-enactment or non-qualification. Where implementation is described as not established, this identifies a limitation of the sources reviewed.
5. Potential reliefs requiring assessment
- The MRA’s September 2026 guide confirms the transitional CbCR safe harbour and describes its extension following the OECD package. Apply the detailed period and eligibility conditions. Separately assess excluded entities and the de minimis exclusion.
- Assess the transitional CbCR safe harbour using qualifying reports and financial data. The OECD extension covers fiscal years beginning on or before 31 December 2027 and ending no later than 30 June 2029. The simplified ETR threshold is 16% for years beginning in 2025 and 17% for years beginning in 2026 or 2027. Confirm domestic application in the jurisdiction applying the rule.
- Subject to eligibility conditions, a jurisdiction can qualify by meeting any one of three transitional CbCR tests: revenue below EUR 10 million and profit before income tax below EUR 1 million; the applicable simplified ETR threshold; or profit before income tax no greater than the substance-based income exclusion. Use the prescribed qualifying data and check the “once out, always out” restriction and its exceptions. These tests differ from the permanent GloBE de minimis exclusion, which generally uses three-year averages.
- Assess the QDMTT Safe Harbour, the Simplified ETR Safe Harbour, the Substance-based Tax Incentive Safe Harbour and relevant entity exclusions separately. Their conditions, elections and effective periods differ. An OECD agreement alone does not establish domestic implementation. Do not assume that Side-by-Side relief applies merely because the group has operations in the United States.
- Relief from top-up tax does not automatically remove registration, notification, return or record-keeping obligations. Retain evidence supporting every relief claimed.
6. Reporting considerations
Annual notification is generally due within six months after the group’s fiscal year ends. A designated Mauritius-resident person files the domestic return and pays the tax within 15 months from the end of the month in which the fiscal year ends, subject to applicable special extensions.
Use the relevant group fiscal year and the MRA’s electronic filing requirements. Assess any safe-harbour reduction in filing requirements separately from notification and supporting-record obligations. The MRA guide describes reduced return requirements in specified cases; a zero tax result should not be treated as eliminating all compliance.
7. Information to prepare
- Ownership chart identifying the ultimate parent, intermediate parents, permanent establishments and ownership percentages.
- Consolidated financial statements and revenue for the four preceding fiscal years.
- Country-by-country reports and the financial records supporting them.
- Jurisdictional accounts, current and deferred taxes, tax incentives, credits and losses.
- Eligible payroll costs and tangible asset carrying values by jurisdiction.
- A compliance register showing responsible entities, elections, registrations and filing deadlines.
- Designated-person details and annual notifications.
- Reconciliations of partial exemptions, foreign tax credits and differing accounting periods.
8. Official sources
- GloBE Model Rules — December 2021OECD
- Consolidated Commentary to the GloBE Model Rules — 2026OECD
- Side-by-Side Package — January 2026OECD
- Central Record for the Global Minimum TaxOECD
- Income Tax Act — consolidated textMauritius Revenue Authority
- Income Tax (QDMTT) Regulations 2026Mauritius Revenue Authority
- Guide on QDMTT — September 2026Mauritius Revenue Authority
These links lead to official legislation, guidance or subject-specific resources. The official texts govern.
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