Mauritius has published the Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026, gazetted on 8 August 2026 and deemed to have come into operation on 1 July 2025. The regulations give detailed effect to the Qualified Domestic Minimum Top-Up Tax (QDMTT) introduced by the Finance Act 2025.
The QDMTT applies to Mauritian constituent entities of multinational enterprise groups whose consolidated annual revenue reaches at least EUR 750 million in at least two of the four fiscal years immediately preceding the relevant year of assessment. The regime covers entities whose accounting period ends on or after 1 January 2025, and it is designed to ensure that in-scope Mauritian profits bear a minimum effective tax rate of 15%.
What the regulations cover
The regulations are aligned with the OECD Global Anti-Base Erosion (GloBE) Model Rules and Commentary. They provide computational and administrative guidance on several matters: the determination of GloBE income or loss, adjusted covered taxes, excluded persons, and transitional rules.
The regulations incorporate the Substance-Based Income Exclusion, covering both the payroll carve-out and the tangible asset carve-out, in line with the GloBE framework. They also introduce the transitional Country-by-Country Reporting safe harbour, which may offer relief to eligible groups during the transition period.
What comes next
With the substantive rules now in force, attention turns to compliance mechanics. The Mauritius Revenue Authority has yet to release the QDMTT return form and associated administrative guidance. Those details will determine how groups operating in Mauritius structure their practical compliance processes.