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On 16 April 2026, The Supreme Court of Mauritius delivered its judgment in UPL Corporation Ltd v The Revenue Tribunal & Anor, bringing long-awaited clarity to the operation of the foreign tax credit (“FTC”) mechanism. The case has its origins in the years of assessment 2013 and 2016/2017, following assessments issued by the Mauritius Revenue Authority (“MRA”) and a subsequent ruling of the Assessment Review Committee (“ARC”) dated 6 April 2023, which had upheld the MRA’s position. At its core, the dispute concerned whether a taxpayer applying the pooling method could combine actual foreign tax suffered with presumed tax across different income streams. The Supreme Court overturned the ARC’s (now Revenue Tribunal) position, rejecting what it described as a “fallacy” and confirming that no such restrictive interpretation exists in law.
The Anti-Money Laundering, Combatting the Financing of Terrorism and Countering Proliferation Financing (Miscellaneous Provisions) Bill (No.III of 2026) (the “Bill”), introduced in the National Assembly on 24 March 2026, introduces wide-ranging reforms across Mauritius’ legal framework, reinforcing the country’s alignment with international standards and strengthening its financial crime enforcement architecture.
The India–Mauritius tax treaty, supported by CBDT Circulars and judicial endorsements, has long provided clarity and a rare degree of certainty in the context of investments held in India via Mauritius. The Supreme Court’s decision in Authority for Advance Rulings v. Tiger Global International Holdings marks a decisive turning point in this narrative, signalling not merely a reinterpretation of treaty provisions but a fundamental recalibration of India’s approach to treaty entitlement, substance, and tax avoidance.
On 1 December 2025, the Judicial Committee of the Privy Council (“the Board”) delivered its judgment in the DirectorGeneral, Mauritius Revenue Authority v Claude Didier de Senneville & Ors [2025] UKPC 57, overturning the decisions of the Assessment Review Committee (“ARC”) and the Supreme Court of Mauritius and restoring the Mauritius Revenue Authority (“MRA”) original income tax assessments.
The Finance Act 2025 has introduced the Fair Share Contribution (FSC) under the Value Added Tax Act, applicable to certain companies for the period 1 July 2025 to 30 June 2028.
The Finance Act 2025 introduces new transfer pricing documentation requirements in Mauritius, marking a major step toward enhanced scrutiny and stricter compliance for companies with related-party transactions. At Andersen Mauritius, we help businesses navigate every stage of their transfer pricing lifecycle, from planning and documentation to implementation and audit support. Our specialists ensure your pricing policies are compliant, defensible, and aligned with your business goals.
The Finance Act 2025 introduces major changes to Mauritius’ VAT regime, extending it to cover digital and electronic services supplied by foreign providers. From 1 January 2026, offshore suppliers of e-books, apps, streaming, hosting, and other online services to Mauritian customers will be required to register for VAT, even without a physical presence in Mauritius.
Mauritius has introduced the Qualified Domestic Minimum Top-Up Tax (QDMTT), effective for assessment years starting on or after July 1, 2025. (i.e. for entities with financial years ending January 2025 and onwards). This legislation aligns with the OECD/G20 BEPS Pillar Two framework.
The Finance Bill 2025 introduces major tax changes and policy updates that will shape Mauritius’ fiscal future. Andersen’s experts have broken down what these mean for businesses and individuals from tax implications to strategic insights.
The Revenue Tribunal Act 2025 (“the Act”) which will come into operation on a date to be fixed by Proclamation marks a major reform in the tax dispute resolution framework of Mauritius.
