The Mauritius government has published substance requirements for the partial exemption regime introduced at the beginning of 2019 to replace the deemed foreign tax credit regime. The new regulations enforce the following provisions:
To determine how income is attributable to a CFC (controlled foreign company).
Entitlement to a 3% preferential tax rate that started on July 1st 2019.
The preferential rate is only applicable to companies:
That carry out their core income generating activities (CIGA) in Mauritius.
That employ a suitable number of qualified staff members to conduct its CIGA.
That incurs a minimum expenditure proportionate to its level of activities.