Transfer Pricing (TP) Compliance Developments in Mauritius - Finance Act 2025

The Finance Act 2025 marks a major shift in Mauritius’s tax and transfer pricing (TP) landscape. Section 75 of the Income Tax Act, which has long required related-party transactions to meet the arm’s length principle, will now be reinforced with mandatory TP documentation effective 8 August 2025. This aligns Mauritius with OECD BEPS standards, requiring companies to maintain detailed records of intercompany dealings. Multinational enterprises, Global Business Companies, and local groups must prepare Local and Master Files, ensure fair pricing, and demonstrate real economic substance.

The Act also introduces the Qualified Domestic Minimum Top-Up Tax (QDMTT), a Fair Share Contribution for high-income individuals, a 10% Alternative Minimum Tax for certain industries, and VAT on digital services from January 2026. These changes highlight Mauritius’s commitment to transparency, global tax alignment, and stricter compliance. Businesses should act now to strengthen governance, mitigate risks, and prepare robust documentation. Click below to download