Challenging a Tax Assessment From the MRA

If the Mauritius Revenue Authority (MRA) issues an assessment you believe is wrong, the law gives you a structured way to contest it. An objection against an MRA assessment in Mauritius is a written, reasoned challenge sent to the Director-General within a strict time limit. It is not a phone call, a complaint or an informal negotiation, and a missed deadline can close the door on the whole process.

This guide explains the sequence of steps, what an objection should contain, how an appeal to the Assessment Review Committee works, and what usually happens to the tax in dispute while the matter is pending. It is general information. The exact time limits and consequences depend on the type of tax and on the wording of your notice, so check both against the current law and, where the amount at stake is significant, take advice before filing.

Where an objection fits in the process

An assessment is the MRA's determination of the tax due for a period. It may follow a return you filed, an estimate made because no return was filed, or a tax review of your records. In each case the notice of assessment is the document that starts the objection clock. Keep the notice, the envelope or electronic delivery record, and the date on which you actually received it.

A company must in any case file its return on time, whether or not it is taxable. Under section 116(1) of the Income Tax Act, the return is due no later than six months after the end of the month in which the financial year closes, and filing and payment are made electronically. A late or missing return is a frequent origin of an estimated assessment, so see corporate income tax return filing before deciding that the assessment itself is the problem.

The MRA publishes the Income Tax Act 1995 consolidated up to the Finance Act 2026. That consolidated text is the reference to read before you rely on any procedural detail.

Objection against an MRA assessment, step by step

Step 1: read the notice carefully

Before anything else, identify what the notice actually says. Check the taxpayer name and number, the period covered, the tax type, the figures, and the date. Compare the amounts with your own accounts and your filed return. Many disputes turn out to be a mismatch of dates, an unrecognised deduction or a figure the MRA took from a third-party source.

Step 2: decide what you really dispute

An objection is stronger when it is specific. Group the points you disagree with:

• a point of law, for example whether an expense is deductible (see which business expenses a company can deduct);
• a point of fact, for example whether a transaction took place or in which period;
• a calculation error, for example a loss not carried forward (see carrying forward a tax loss).

If part of the assessment is correct, say so. Contesting everything weakens credibility and may slow the review.

Step 3: lodge the objection in time

The deadline is set by the law and is counted from the date of the notice or its service, depending on the provision that applies. This page deliberately gives no number of days: read the notice and the relevant section of the Income Tax Act, and diarise the last day with a safety margin. Treat the deadline as strict. If you are already late, the first question for an adviser is whether any provision allows the MRA to accept a late objection, and on what conditions.

What the objection should contain

The objection must be in writing and addressed to the Director-General. The notice itself and the statute govern the exact format, and the MRA may provide a form or an online channel, so confirm which applies to your tax type. A well-built objection normally includes:

1. your identification details and the tax and period concerned;
2. a reference to the notice of assessment and its date;
3. each ground of objection, stated precisely and separately;
4. the amount you believe is correct, with a short calculation;
5. supporting documents, indexed and referenced in the grounds;
6. a signature by a person authorised to act for the company.

Avoid general statements such as "the assessment is excessive". A ground that does not say why the assessment is wrong may be treated as not properly stated.

For a company, the person who signs should be someone with authority under the board's decision. The board's minutes or a written resolution authorising the objection are good practice (see board resolutions). If a registered agent or corporate service provider handles your tax communications, the engagement terms should say who prepares and files objections, and who bears the cost.

After the objection: the MRA's decision

Once received, the objection is reviewed. The MRA may request information, invite a meeting, amend the assessment or confirm it. Respond to every request promptly and in writing, and keep a copy of everything sent.

Possible outcomes are:

• Assessment reduced or cancelled, in whole or in part, with a revised notice;
• Assessment confirmed, with a written decision;
• Partial agreement, with the remaining points staying open.

A written decision, or the passing of the time allowed for one, usually opens the next stage. Check what the statute says on both situations, because the consequences of silence are set by law and not by what the MRA tells you by phone.

Appealing to the Assessment Review Committee

If you remain dissatisfied, the next stage is an appeal to the Assessment Review Committee, an independent body that examines disputes between taxpayers and the MRA. Searching for "assessment review committee mauritius" or "appeal tax assessment mauritius" leads to this stage, but keep in mind that a valid appeal normally depends on you having first objected properly.

In practical terms:

• the appeal is made in writing within the time allowed after the MRA's decision;
• it identifies the assessment, the decision under appeal and your grounds;
• the grounds should match those in the objection, since new arguments may be challenged;
• the Committee hears both sides and issues a determination;
• representation by a qualified professional is common, especially for technical issues.

Prepare as for a hearing: a short chronology, a clean set of documents, a computation both sides can follow, and a clear statement of what you ask the Committee to decide. If the determination is unfavourable, the law may provide a further route to the courts, usually limited to defined grounds. An adviser should confirm the route, the time limit and the cost implications before you go further.

What happens to payment while you object

This is where many companies go wrong. Filing an objection does not, by itself, assume that the tax stops being payable. The general position is that tax assessed remains due by its date, and the rules on whether payment can be suspended or deferred, in full or in part, depend on the provision and on the MRA's discretion. Do not assume that lodging an objection pauses collection.

What to do in practice:

• read the notice for a payment date and for any statement about disputed tax;
• if you accept part of the assessment, consider paying the undisputed part on time;
• if you want to defer the disputed amount, ask in writing and obtain a written answer;
• keep proof of every payment and of every request;
• if the outcome is in your favour, ask how an overpayment will be refunded or credited.

Interest and penalties may accrue on tax that stays unpaid. They are covered in penalties for non-compliance and are not repeated here. For companies under the quarterly instalment regime, see the advance payment system, since the instalments interact with the final liability.

Settling the matter in good time also matters for other steps in the life of the company. A tax clearance certificate may be required for some transactions, and a voluntary striking-off needs a letter of non-objection from the Director-General of the MRA, which is difficult to obtain with an open dispute.

Choosing between objecting and correcting

Not every disagreement needs a formal challenge. Use this short decision aid.

Checklist before you file

• The notice of assessment and its date of service are on file
• The last day for objecting is diarised, with a margin
• Each ground is stated separately and precisely
• Your own computation is attached and reconciled to the MRA figures
• Supporting documents are indexed and legible
• An authorised signatory has approved and signed
• The payment position for undisputed and disputed tax is decided
• Proof of filing and of delivery is kept
• Records are retained in line with record-keeping rules

Keeping the dispute manageable

Good internal records shorten any dispute. Maintain clean bookkeeping, reconcile your returns to your financial statements, and file through the MRA's electronic channels so there is a clear timestamp (see filing with the MRA online). Where the same issue could recur in later years, resolve it in the dispute, since the outcome often guides the following assessments.

If you want a professional view on your own assessment, you can send a request through the site's form. The request is relayed to an FSC-licensed corporate service provider (Management Licence), which can advise on your situation.