The Mauritius Finance Bill 2026 (No. XII of 2026) and the accompanying Economic and Financial Measures (Miscellaneous Provisions) Bill 2026 (No. XIII of 2026) give legislative shape to the Budget Speech 2026–2027. Together they introduce sweeping changes across corporate tax, international tax frameworks, incentive regimes, and withholding obligations. This analysis focuses on the provisions most relevant to tax practitioners advising on Mauritius structures.
Corporate Climate Responsibility Levy: payment mechanics and credit restrictions
The Corporate Climate Responsibility (CCR) Levy, a 2% charge on a company's chargeable income, was introduced ahead of this Bill. The Finance Bill now refines how it is paid and which credits may reduce it.
Companies that file Advance Payment System (APS) statements must pay the CCR Levy in four quarterly instalments. The first three instalments, each equal to 25% of the levy computed on chargeable income under section 50C of the Income Tax Act (ITA), are due with each APS statement. The final 25% is payable with the annual income tax return under section 116 of the ITA.
A transitional relief schedule reduces the amounts payable under APS statements:
- 75% reduction for APS statements due between 1 July 2026 and 30 June 2027
- 50% reduction for statements due between 1 July 2027 and 30 June 2028
- 25% reduction for statements due between 1 July 2028 and 30 June 2029
On the credit side, the Bill provides that no tax credit may reduce the CCR Levy, other than the specified manufacturing tax credit and any credit available under a Double Taxation Agreement (DTA). This restriction has immediate consequences for companies receiving foreign-source income.
DTA protection and the foreign tax credit gap
Under the ordinary Mauritius corporate income tax framework, a company receiving foreign-source income, such as dividends, may credit foreign withholding tax and underlying corporate tax against its 15% Mauritius tax liability on that income, subject to the treaty's limitation rules. The CCR Levy restriction does not disturb that ordinary credit. However, the same foreign tax credit cannot be applied to reduce the additional 2% CCR Levy unless a DTA expressly requires Mauritius to grant relief.
Where a DTA does apply and the foreign tax suffered is sufficient to cover both the 15% corporate tax and the 2% CCR Levy, the investor may be fully sheltered. The outcome depends on the specific allocation and limitation provisions of the treaty in question.
Where no DTA exists, the position is straightforward and less favourable. The CCR Levy becomes an unrelieved additional cost. Foreign taxes suffered in the source country cannot be credited against it, producing an effective 2% surcharge on income already taxed abroad. This is a material concern for investments into African jurisdictions not covered by Mauritius's treaty network. Practitioners structuring pan-African investment platforms through Mauritius should assess treaty coverage carefully before and after the gazette date on which these provisions take effect.
QDMTT: technical refinements
The Qualified Domestic Minimum Top-up Tax (QDMTT) framework is adjusted on several fronts. The definitional changes include updating the "covered person" reference to section 50Q, narrowing "excluded person" to investment funds and real estate investment vehicles only where they are ultimate parent entities, clarifying that "financial accounting net income or loss" encompasses intra-group adjustments, and amending "fiscal year" to include the calendar year where the deemed consolidation test is met.
Filing and payment obligations are also adjusted. Returns must be submitted within 15 months, and the period within which an amended return may be filed is extended from two to three years. The penalty for late or incorrect filing is reduced from 5% to 2.5%.
The penalty reduction takes effect from the gazette date. The definitional, filing, and assessment changes are deemed effective from the year of assessment commencing 1 July 2025.
Global business entity definition: foundations and trusts
Section 2 of the ITA is amended to narrow the criteria under which foundations and trusts qualify as global business entities. The changes apply from the year of assessment commencing 1 July 2027.
A foundation qualifies only where the founder is a non-resident or holds a Global Business Licence, all beneficiaries appointed under the charter or will are non-residents or hold a Global Business Licence throughout the income year, and the foundation's purpose is carried out outside Mauritius.
A trust qualifies only where the settlor is a non-resident or holds a Global Business Licence, all beneficiaries appointed under the trust deed are non-residents or hold a Global Business Licence throughout the income year, and the trust is a purpose trust under the Trusts Act with its purpose carried out outside Mauritius.
Trustees of unit trust schemes who are non-residents or hold a Global Business Licence are added to the definition. Practitioners should review existing structures against these criteria well before July 2027.
Incentive regimes: extensions, introductions and repeals
Manufacturing tax credit. The 15% tax credit on capital expenditure by manufacturing companies on new plant and machinery, artificial intelligence, and patents is extended from 30 June 2026 to 30 June 2029. Unrelieved credits may be carried forward for ten years. This takes effect from the gazette date.
Captive insurance. The ten-year income tax exemption for captive insurers licensed before 19 June 2026 may be extended by up to five further years from the expiry of the original period, subject to substance requirements.
EDB Investment Certificate holders. The eight-year income tax exemption period now begins in the income year in which the company starts operations, rather than the year of incorporation.
Start-up enterprises. A ten-year income tax exemption is introduced for start-up enterprises set up on or after 19 June 2026, managed in Mauritius, conducting operations in Mauritius or Africa, supported by an accredited incubator under the National SME Incubator Scheme of the Mauritius Research and Innovation Council, and with annual turnover not exceeding MUR 100 million.
Repeals from 1 July 2027. Two enhanced deductions are removed: the 150% deduction on expenditure by hotels on cleaning, renovation and embellishment works in the public realm, and the 200% deduction on expenditure by higher education institutions on joint tertiary education contracts with African universities.
CSR remittances and live animal exports
The minimum percentage of a CSR Fund that must be remitted to the Mauritius Revenue Authority increases to 75% for funds established on or after 1 January 2027. The 50% minimum continues to apply to funds set up between 1 January 2026 and 31 December 2026.
Separately, the definition of "export of goods" in section 2 of the ITA is amended to exclude live animals. The reduced 3% corporate income tax rate on export profits will therefore no longer be available on income from the export of live animals, effective from the gazette date.
ICT services: source rules and new withholding obligations
Income derived from specified ICT services supplied in Mauritius will be treated as Mauritius-source income. The specified services are: supply of software, software licences, software applications, software maintenance services, and distance maintenance of programmes and ICT equipment.
Two new tax deduction at source (TDS) obligations are introduced from the gazette date:
- Payments to an ICT services provider for the above services exceeding MUR 300,000: TDS at 1%
- Payments for advertising, promotional, endorsement, or marketing services through social media platforms, digital content, or similar electronic means: TDS at 5%
Where either payment is made to a non-resident, the rate may be reduced under the applicable DTA. Businesses making such payments will need to assess whether they cross the MUR 300,000 threshold and implement appropriate withholding processes before the gazette date.