Partial Exemption Regime

Further to the amendments brought by the Finance Act 2019, the Income tax regulations were amended to provide clarity on conditions to be met by resident companies to avail of the Partial Exemption Regime (“PER”). (Refer to Sub Part B and C Part II of the Second Schedule of the Income Tax Act).

Among the changes brought about by the Finance (Miscellaneous Provisions) Act 2019, Global Business Companies (“GBCs”) shall now be required to carry out their Core Income Generating Activities (“CIGA”) in, or from, Mauritius, as required under the Income Tax Act.

This implies that the CIGA requirement now falls under the purview of the Mauritius Revenue Authority (“MRA”).

Please see below table for more details:

Please note that the minimum expenditure and employment criteria circular letter (which is no longer available on the FSC website) will still be applicable for non-investment holding entities (Minimum expenditure USD15,000 and if turnover is less than USD100M- 1 employee; if turnover is above USD100M- 2 employees)


Freeport operators or private Freeport developers engaged in the export of goods or manufacturing activities in a Freeport zone and wishing to avail of the reduced tax rate of 3% will need to abide by the following conditions:

  • Employ a minimum of 5 staff; and
  • Incur an annual local expenditure exceeding Rs 3.5 million

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