Amends tax laws to introduce several investment-related provisions, including in the context of BEPS 2.0

02 Aug 2022

On 2 August 2022, Mauritius adopted the Finance (Miscellaneous Provisions) Act 2022, which provides for the implementation of measures announced as part of the 2022-2023 Budget. The main investment-related measures include:

• 8-year income tax holidays granted from 1 July 2022 on income derived by a newly established freeport operator or developer making an investment of at least MUR 50 million; • Increase from 10% to 25% of the additional deduction for amounts incurred by large manufacturers to purchase locally manufactured products from SMEs (annual turnover not exceeding MUR 100 million); • The Income Tax Act (ITA) amendment to cater for any change that may be required in connection with the introduction of a domestic minimum top-up tax, applicable to companies resident in Mauritius forming part of MNE groups with global annual revenue of EUR 750 million or more, to ensure that they are taxed at the global minimum rate of 15%, including (i) the addition of relevant definitions and references to the GloBE Rules as approved by the Inclusive Framework on BEPS; and (ii) the addition of the provision that, notwithstanding the other provisions of the ITA, a company forming part of an MNE group that is liable to a Top-up Tax in a year, may be required by the Director-General to compute and pay a Qualified Domestic Minimum Top-up Tax in such form and manner as may be prescribed;

Where the effective date of the measures is not specified, they are generally effective from 2 August 2022.