The Mauritius Income Tax Act has recently been amended to grant Mauritius tax holidays to corporates licensed by the Financial Services Commission (FSC) and to individuals who are in employment with specific licensed corporations.
These long-awaited measures have now been enacted through Regulations and we are pleased to provide you with details of the relevant requirements as specified by the FSC in its circular issued on 23 December 2016.
Categories of licensees availing Mauritius tax holidays
- Global Headquarters Administration
- Global Treasury Activities
- Overseas Family Office (Single)
- Overseas Family Office (Multiple)
- Investment Banking
- Global Legal Advisory Services
Conditions to be met by corporates to benefit from the Mauritius tax holidays:
- Licenses granted on or after 01 September 2016
- Income is derived from Activities covered under that license
- Minimum employment and requirements of the FSC relating to the substance of the business activities (please refer to below table for details)
| Licenses | Tax Holidays
|
Conditions | |||
| Physical Office in Mauritius | Minimum No. of employees resident in Mauritius | Asset under Management | Minimum annual operating expenditure | ||
| Global Headquarters Administration | 8 years | Required | 10 professionals with at least 2
at managerial positions |
N/A | MUR 5 million (approx. USD 139k) |
| Global Treasury Activities | 5 years | Required | 4 professionals with at least 1 at
managerial position |
N/A | MUR 2 million
(approx. USD 55k) |
| Overseas Family Office (Single) | 5 years | Required | 1 professional | >USD 5 million | N/A |
| Overseas Family Office (Multiple) | 5 years | Required | 3 professionals | >USD 5 million per family | N/A |
| Investment Banking | 5 years | Required | 5 professionals | N/A | MUR 5 million
(approx. USD 139k) |
| Global Legal Advisory Services | 5 years | Required | 5 lawyers | N/A | N/A |
Individuals
5 Years Tax Holidays on emoluments derived by an employee/officer in employment with a corporation duly licensed by the FSC as ‘CIS Managers’ and ‘Asset Management Companies’.
The officer should be approved by the FSC under section 24 of the Financial Services Act and should be issued with one of the following certificates* by the FSC on or after 01 September 2016:
- An Asset Manager Certificate
- A Fund Manager Certificate
- An Asset and Fund Manager Certificate
Conditions to be satisfied for eligibility of above certificates are as follows:
- The officer must be resident in Mauritius
- The asset base being managed must be an average of USD100 million over the last financial year; and
- The employer must submit a declaration to the FSC, signed by the directors and the corporate auditors, confirming that the officer has managed an asset base averaging USD100 million over the last financial year
*The Certificate will be issued on an annual basis and the 5 year tax holiday is valid as from the income year in which the officer was granted the relevant certificate(s) by the FSC.
Board of Investment
The tax exemptions are subject to the terms and conditions of the Board of Investment.
How we can assist
- Assess your eligibility for the above tax holidays
- Application and liaison with the regulators for the relevant licenses
- Assist in the recruitment of the relevant officers
- If required, assist in relocation of Officers
- Applying for Occupational or Investor permit with the Board of Investment
- Assist with the ongoing compliance