Double Taxation Agreements

Mauritius's treaty network: a strategic asset

With 45 double taxation agreements (DTAs) in force (MRA, 2026), Mauritius positions itself as one of the most fiscally well-connected jurisdictions in the world, relative to its size. This treaty network constitutes a decisive competitive advantage for companies and investors who choose Mauritius as a base for their international operations.

Tax treaties eliminate or reduce the double taxation that arises when the same income is taxed in two countries. They set reduced withholding tax rates on dividends, interest and royalties, and determine the rules for allocating taxing rights between the signatory States. Almost all Mauritian DTAs are based on the OECD Model, incorporating the anti-abuse clauses of the BEPS project.

Full table of Mauritius's tax treaties

The table below presents all of Mauritius's double taxation agreements in force, with the withholding tax (WHT) rates applicable to dividends, interest and royalties. The rates shown are the reduced treaty rates; in the absence of a treaty, the source country's domestic rates apply.

Europe

Asia and Pacific

Africa

Middle East

Other regions

Focus: the Mauritius-France treaty

The treaty between Mauritius and France is of particular importance for French-speaking entrepreneurs. Initially signed in 1980 and revised on several occasions, it offers a favourable tax framework for Franco-Mauritian investments.

Key points of the Mauritius-France DTA

• Dividends: withholding tax reduced to 5% (direct shareholding of at least 10% of capital) or 15% (other cases), instead of higher domestic rates
• Interest: full exemption (0%) from withholding tax in both directions
• Royalties: full exemption (0%) from withholding tax
• Capital gains on shareholdings: taxable only in the State of residence of the transferor (Mauritius = 0% capital gains tax)
• Permanent establishment: definition in line with the OECD model, with a 12-month threshold for construction sites

Practical application: a Mauritian holding company for African investments

A French entrepreneur who sets up an investment holding company in Mauritius to manage their African investments benefits from an optimised tax circuit:

1. Dividends from African subsidiaries to Mauritius

   Reduced withholding taxes thanks to Mauritius's African DTAs (often 0-10% vs. 15-25% without a treaty).

2. Taxation in Mauritius

   Dividends received benefit from the 80% partial exemption, resulting in an effective rate of only 3%.

3. Redistribution to France

   Dividends from Mauritius to France bear only a 5% withholding tax (Mauritius-France DTA, 10%+ shareholding).

4. Capital gains on disposals

   Capital gains on the disposal of African shareholdings are not taxed either in Mauritius (0% capital gains) or potentially in France (parent-subsidiary regime, subject to conditions).

Focus: the Mauritius-India treaty (revised)

The Mauritius-India treaty was for a long time one of the most widely used tax treaties in the world. For more than 30 years, it allowed investors to access the Indian market via Mauritius with virtually no taxation on capital gains. The 2016 revision substantially changed the treatment of capital gains.

Evolution of the treatment of capital gains on Indian shares

Remaining advantages of the Mauritius-India treaty

Despite the revision, the treaty retains significant advantages:

• Dividends: withholding capped at 5% (direct shareholding of 10%+) instead of 10-20% under Indian domestic law
• Interest: withholding capped at 7.5% instead of 5-40% under domestic law
• Indian debt securities: interest income on certain Indian debt securities remains exempt
• Technical services: certain services are not treated as royalties under the treaty, escaping domestic withholding

Mauritius, a hub for investment in Africa

Mauritius's network of African treaties is arguably its most distinctive asset. While few international jurisdictions have extensive DTAs with African countries, Mauritius offers exceptional coverage that makes it the preferred gateway for investment on the continent. The positioning of Mauritius as an African financial hub is largely based on this unique treaty network.

Typical structure: investing in Africa via Mauritius

1. The investor (European, Asian or Middle Eastern) holds a Mauritian GBC
2. The GBC holds direct shareholdings in operating companies in Africa
3. Dividends flow up to Mauritius with reduced withholding (0-10% depending on the DTA vs. 15-25% without a treaty)
4. In Mauritius, these dividends benefit from the 80% partial exemption (effective rate of 3%)
5. Dividends redistributed to the investor bear no withholding tax (0% Mauritian WHT)
6. Capital gains on the disposal of African shareholdings are exempt in Mauritius (0% capital gains tax)

The Tax Residence Certificate (TRC)

To invoke the provisions of a double taxation agreement, a Mauritian company must obtain a Tax Residence Certificate (TRC) issued by the Mauritius Revenue Authority (MRA).

Conditions for obtaining the TRC

• The company must be incorporated in Mauritius or have its place of effective management there
• It must demonstrate sufficient economic substance (at least 2 resident directors, staff, premises)
• It must be up to date with its tax obligations (filings and payments up to date with the MRA)
• Strategic decisions must be made in Mauritius (documented board meeting minutes)
• The company must have a bank account in Mauritius with real financial flows

Procedure and timeline

The TRC application is filed with the MRA together with supporting documents (financial statements, proof of substance, details of resident directors). Processing time is 5 to 10 working days. The certificate is valid for one financial year and must be renewed annually. The MRA may request additional information if the substance conditions are not clearly demonstrated.

Mechanisms for eliminating double taxation

In practice, Mauritius's Partial Exemption System often provides a greater advantage than the treaty tax credit, since it reduces the taxable base by 80% regardless of the amount of tax actually paid abroad. The two mechanisms are complementary and apply according to the specific provisions of each treaty.

Multilateral Instrument (MLI) and anti-abuse clauses

Mauritius is a signatory to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), adopted under the OECD's BEPS project. The MLI makes it possible to simultaneously amend all bilateral treaties to incorporate the following anti-abuse measures:

• Principal Purpose Test (PPT): treaty benefits may be denied if obtaining those benefits was one of the principal purposes of an arrangement or transaction
• Limitation on Benefits (LOB): some treaties include clauses limiting the beneficiaries eligible for treaty benefits
• Permanent establishment rules: an expanded definition to cover artificial arrangements designed to avoid permanent establishment status
• Mutual agreement procedure: strengthened mechanisms for resolving disputes between tax administrations

Evolution of the treaty network

Mauritius continues to expand and modernise its network of tax treaties. Current geographic priorities include:

• Strengthening treaties with West African countries (ECOWAS) — Côte d'Ivoire, Cameroon
• Expansion towards Latin America (Brazil, Argentina, Colombia)
• Updating existing treaties to align them with the 2017 OECD model and BEPS recommendations
• Developing new treaties with emerging economies in Southeast Asia, reinforcing the role of Mauritius as a gateway to Asia