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The Finance Act 2025 is Mauritius's comprehensive annual omnibus statute amending the principal financial-sector laws to implement the June 2025 Budget and operationalise Mauritius's obligations under several international frameworks simultaneously.
The cornerstone provision introduces a Qualified Domestic Minimum Top-Up Tax (QDMTT) under the Income Tax Act, aligned with the OECD/G20 Inclusive Framework Global Anti-Base Erosion (GloBE) Pillar Two rules. Scope: MNE groups with consolidated annual revenue of EUR 750 million or more in at least two of the preceding four fiscal years — the same revenue threshold as the EU Pillar Two Directive (Council Directive 2022/2523) and peer national implementations (UK, Korea, Canada, Australia, UAE, Singapore, Hong Kong, Vietnam, Switzerland). The QDMTT applies to financial years ending after 31 December 2024; for Mauritius corporate filers (standard July-June fiscal year), the first year of assessment subject to QDMTT is the year commencing 1 July 2025.
The QDMTT mechanism: Mauritius computes a jurisdictional top-up tax equal to the difference between 15% and the effective tax rate on qualifying Mauritius profits of covered MNE constituent entities. Because Mauritius QDMTT is a QUALIFIED domestic minimum top-up tax (meeting GloBE safe-harbour criteria), parent-jurisdiction IIR / UTPR charges on the same Mauritius profits are displaced — the tax revenue stays in Mauritius rather than flowing to the MNE's headquarter jurisdiction. This is operationally equivalent to the UAE QDMTT (Cabinet Decision 142/2024, filed) and Singapore Multinational Enterprise (Minimum Tax) Act 2024 (filed).
Offshore-FC implication: Mauritius has historically charged 15% corporate tax on GBCs (with the 80% partial-exemption effectively reducing the rate to 3%). The Finance Act 2025 restructures GBC taxation to comply with GloBE substance-based income exclusion (SBIE) rules, meaning MNE-owned GBCs must demonstrate genuine economic substance or face the full 15% effective rate. This is the most material structural change to Mauritius's offshore-FC competitive model since the 2018-2019 Indian DTAA renegotiation removed treaty shopping via the MU-IN tax-treaty channel.
New fiscal incentives under the Income Tax Act for:
qualifying investments in AI infrastructure hosted in Mauritius — positions MU as a competing AI-services hosting jurisdiction alongside Singapore, UAE, and BVI.
Services Commission of Mauritius (FSC-MU) under the Virtual Asset and Initial Token Offering Services (VAITOS) Act 2021 — covering custodians, exchanges, and transfer agents. This operationalises UNCTAD's finding that Mauritius is positioning as a leading African crypto-asset regulated-hub jurisdiction.
Amendments to beneficial-ownership identification, verification, and record-maintenance requirements, aligned with FATF Recommendation 24 (transparency of legal persons) standards and the June 2024 FATF fourth-round mutual evaluation of Mauritius (which reviewed the adequacy of UBO registers following Mauritius's 2020-2021 grey-listing remediation and June 2022 FATF white-listing).
Tightened substance and economic-presence requirements for Global Business Companies (GBC 1 / GBC 2 successor GBC regime under the 2019 FSA amendments). GBCs must demonstrate resident directors with local decision-making authority, adequate local staff, and local operational expenditure — consistent with OECD BEPS Action 5 substantial-activity requirements and the EU Code of Conduct Group standards that informed Mauritius's removal from the EU list of non-cooperative jurisdictions for tax purposes in 2021 (and 2022 for AML purposes).
The Financial Intelligence and Anti-Money Laundering Act amendments expand:
accountants, lawyers, real-estate agents, jewellers, FSC licensees);
The Financial Services (Framework for the Imposition of Administrative Penalties) (Amendment) Rules 2025 introduces escalating penalty tiers for FSC licensees (asset managers, collective investment schemes, global business companies, securities brokers) for regulatory non-compliance, replacing the prior fixed-penalty structure.
inbound FDI via the MU-IN DTAA prior to the 2016-2017 renegotiation that removed capital-gains treaty benefits. The surviving GBC route (dividend income, interest income under updated treaty) is now further tightened by the QDMTT + GBC substance requirements. Expect continued gradual migration of India-bound PE/VC structures to Singapore and Cayman.
for private-equity and venture-capital funds investing into sub-Saharan Africa (Standard Bank, Actis, Helios, Convergence Partners all use MU GBC structures). The GBC substance-tightening forces local-director upgrades and operational-expenditure increases — marginal cost increase for the MU-Africa PE corridor.
asset business from UAE (which is simultaneously tightening VASP oversight under VARA) and from Seychelles / BVI (which lack equivalent regulatory clarity for institutional VASPs).
offshore-FC architecture is now anchored in the register, enabling responds_to graph edges for future MU regulatory filings.
may differ — the Act contains both retrospective (QDMTT from FY ending 31 Dec 2024) and prospective provisions; FSC implementing rules may have separate commencement dates.
likely to specify enforcement timetables; watch fscmauritius.org for circulars Q4 2025.
Framework (so that IIR/UTPR jurisdictions accept MU as displacing top-up rights) — KPMG's alert treats this as intended but confirms that formal peer-review by the OECD Inclusive Framework is the determinative gate.