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International Tax
Transfer Pricing & Country-by-Country Reporting in Mauritius (2025)
Mauritius does not have a dedicated TP code, but the arm's-length principle is enforced through Section 75 of the Income Tax Act. Here's how compliance actually works in 2025.
Anexa Biz Jul 11, 2025 12 min read
The Mauritian TP framework
Section 75 of the Income Tax Act empowers the MRA to adjust income where transactions between related parties are not at arm's length. Mauritius has not enacted OECD Chapter V master file/local file rules but the MRA references the OECD Transfer Pricing Guidelines when reviewing structures.
CBCR obligations
- MNE groups with consolidated turnover ≥ €750M file a Country-by-Country Report.
- Mauritian entities that are the ultimate parent file the CBCR with the MRA.
- Constituent entities file a CBCR notification within 12 months of year-end.
Practical documentation expectations
- Functional analysis of the intercompany transaction.
- Comparability study using a recognised database (Amadeus, TP Catalyst).
- Choice-of-method memo (usually TNMM for services).
Frequently asked questions
Q. Are there fixed TP penalties in Mauritius?
There are no bespoke TP penalties, but general assessment, interest and tax-shortfall penalties apply if the MRA restates related-party pricing.