On 2 October 2026, the Mauritius Revenue Authority (MRA) released an electronic booklet titled “Guide on Qualified Domestic Minimum Top-up Tax (QDMTT)” to assist multinational enterprise groups in understanding and complying with the new Domestic Minimum Top-up Tax (DMT Tax) regime. This guidance aligns with the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) Pillar Two rules, which Mauritius has committed to implementing. The QDMTT ensures that excess profits of constituent entities located in Mauritius are subject to a minimum effective tax rate of 15%, preventing profit shifting to low-tax jurisdictions. The guide outlines the scope, calculation mechanics, filing obligations, and transitional provisions applicable for fiscal years beginning on or after 1 July 2026.
Key Takeaways
- Scope and Applicability: The QDMTT applies to multinational enterprise groups with annual consolidated revenue of €750 million or more in at least two of the four preceding fiscal years. It covers all constituent entities resident in Mauritius, including permanent establishments.
- Calculation and Crediting Mechanism: The top-up tax is computed as the difference between the 15% minimum rate and the group’s effective tax rate in Mauritius, applied to the qualifying income. The guide details the qualified domestic minimum top-up tax credit mechanism to avoid double taxation.
- Compliance and Filing Requirements: Affected groups must submit a QDMTT return within 15 months after the end of the fiscal year (or 18 months for the first year). The MRA emphasizes the need for robust data collection systems to capture financial accounting information and tax adjustments required for the Pillar Two computation.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement