Preparing for an MRA Tax Review

An MRA tax audit of a company in Mauritius is a request by the Mauritius Revenue Authority (MRA) to examine whether the figures in a tax return are supported by the facts and by the law. It can be a short query on a single item or a wider examination of a whole year. In both cases the outcome depends mostly on one thing: whether the company can show, with documents, why it reported what it reported.

This page explains what tends to draw attention, what the MRA is likely to ask for, and how to build a file that supports your position. It gives general information. How a review unfolds depends on the company, the year and the issue raised, so a specific case needs an adviser's analysis.

What a tax review actually is

A review starts from the return. The MRA compares what a company declared with what it can see elsewhere: earlier years, third-party information, payments made, other taxpayers in the same sector. Where something does not fit, it may ask questions or request supporting papers.

The company's task is not to prove everything in advance. It is to be able to answer, quickly and with evidence, for any material figure. That is a record-keeping discipline more than a crisis response. If your bookkeeping and records are in order during the year, a review becomes a retrieval exercise.

What can trigger a review

There is no public list of triggers, and nothing here should be read as a guarantee that a clean return will never be queried. Experience suggests several patterns that make a return stand out.

A company that fits none of these can still be selected, and a company that fits several may never hear from the MRA. The practical lesson is not to avoid certain activities but to be ready to explain them.

Residence and status: the first thing to settle

Many questions in a review begin with status, because the rules that apply depend on it. Under the Income Tax Act, a company is resident in Mauritius for tax purposes if it is incorporated in Mauritius or if its central management and control are in Mauritius (section 73).

A company incorporated in Mauritius is treated as non-resident if it is centrally managed and controlled outside Mauritius (section 73A). Such a company must still file an income tax return under section 116. Anyone running a Mauritian company from abroad should keep evidence of where decisions are really taken, because that evidence is what supports the claimed status. The board meetings and minutes are a natural place to show it.

A company that needs formal proof of residence can apply to the Director-General for a Tax Residence Certificate. It is issued within 7 days of the application, provided the required income tax return has been filed and the fee has been paid. The fee is set in the Income Tax Regulations 1996 (article 20A): MUR 1,000 for an individual, USD 1,000 for a CIS and USD 200 in other cases. Note that the certificate depends on a return having been filed, which is one more reason to keep the filing record clean.

Global business entities (a holder of a Global Business Licence from the FSC, or a company with an authorisation under section 71A of the Financial Services Act, known as an Authorised Company) sit within their own regime and are treated differently by several provisions. Check which regime applies before assuming that a rule discussed in general terms covers you.

Which rules you may be asked to apply

A review tests the application of rules to your numbers. The ones below come up most often in questions about a company's return. The Income Tax Act is published in consolidated form by the MRA, up to the Finance Act 2026, and that text is the reference for current rates and thresholds.

• Standard rate. The standard corporate rate is 15% of chargeable income, under the First Schedule, Part IV, for income years starting on or after 1 July 2010.
• Reduced rate for exporters of goods. A reduced rate of 3% applies to companies exporting goods (First Schedule, Part II), in force since 1 July 2017 according to the MRA. Since the Finance Act 2026 (effective 13 August 2026), the export of live animals is excluded from the definition of "export of goods", while international trading of goods shipped directly between two countries without a physical stop in Mauritius, and the sale of aviation fuel to an airline, are included. Claiming the reduced rate means being ready to show that the activity falls within that definition.
• Alternative Minimum Tax (section 44A). If a company's normal tax is below 10% of its adjusted book profit, the tax due equals 10% of that adjusted book profit. It applies from the income year starting on 1 July 2026. It does not apply to a global business entity (a GBC or an Authorised Company); it targets hotels, insurers, financial intermediaries, property companies and telecommunications companies.
• Corporate Climate Responsibility (CCR) Levy. The levy is 2% of chargeable income for any company, for the income year starting on 1 July 2024 and each following year (section 50O). It is not due where turnover for the year does not exceed MUR 50 million. Since the Finance Act 2026, companies under the APS system pay it in three instalments of 25% with their APS returns, and the balance with the annual return; others pay with the annual return. No tax credit can reduce it, apart from the credit under section 161A(58A) and a credit under section 76.
• Corporate Social Responsibility. Each company must set up a CSR fund equal to 2% of the previous year's chargeable income (section 50L). The share to be remitted to the MRA is at least 75% for funds set up from 2019 to 31 December 2025, at least 50% for those set up from 1 January to 31 December 2026, then at least 75% from 2027; the rest funds CSR programmes. See CSR contribution for Mauritian companies.
• Tax losses. Losses may be carried forward over the following five income years, with a restriction if shareholding changes by more than 50%. Certain losses (capital allowances, deep ocean water projects, research and development) carry forward without a time limit. The origin of a loss is a common question, so see carrying forward a tax loss.
• Dividends. Dividends paid by a Mauritian-resident company are exempt from income tax in the hands of the recipient (Second Schedule, Part II, Sub-part B, item 1), and no withholding is provided for on them.

The Fair Share Contribution, another charge on larger companies, has its own conditions. It applies to companies with chargeable income above MUR 24 million in the year, the turnover criterion having been removed by the Finance Act 2026. It is 5% of chargeable income for a company taxed at 15% and 2% for a company taxed at 3%, on income from 1 July 2025 to 30 June 2028, and no credit under the Income Tax Act reduces it (VAT Act, section 53N(5)).

Build the file before you are asked

The best preparation is a standing file for each income year. The aim is a short path from any figure in the return back to a source document.

The core documents

Keep, at a minimum, the following for each year.

• The filed return, the computation of chargeable income and the working papers behind it
• The approved financial statements and, where relevant, the audit file
• The general ledger, bank statements and reconciliations
• Sales and purchase invoices, contracts and engagement letters
• Evidence for each material deduction: purpose, amount and link to the business
• Fixed asset register and support for capital allowances
• Board minutes and resolutions approving key decisions, dividends and related-party dealings
• Proof of payment of tax, APS instalments, CSR and any levy due
• Payroll records and returns that agree with the accounts
• Evidence of where management and control are exercised

For deductions, see which business expenses a company can deduct. A cost with no invoice, no description and no link to the business is the one most likely to be disallowed.

Write a position note for each judgement

Where the law leaves room for interpretation, a short written note made at the time of filing is worth more than an explanation reconstructed years later. It should state the facts, the provision relied on, the reasoning and who approved it. It does not have to be long. It shows the MRA that the position was considered rather than improvised.

Keep the paper trail consistent

Inconsistency between documents is a common source of difficulty. The accounts, the tax computation, the payroll returns and the minutes should tell the same story. If you change a treatment from one year to the next, record why.

If the MRA writes to you

A request for information is not an accusation. Treat it methodically.

1. Read it carefully. Identify the years, the issues and the deadline given in the letter. Do not rely on memory of other cases.
2. Log it. Record the date of receipt, who handles it and each deadline.
3. Answer what is asked. Provide the documents requested, indexed and legible. Avoid volunteering unrelated material.
4. Keep your answers consistent. What you say must match the filed return and the accounts.
5. Ask for time if needed, in writing. Do not let a deadline pass without a response.
6. Take advice early on any significant issue. The point is to shape the file, not to react after a position has hardened.

If the MRA then issues an assessment you disagree with, a separate procedure applies; see challenging a tax assessment from the MRA. The consequences of missing filings or payments are covered in penalties for non-compliance in Mauritius.

Who prepares the file

The directors remain responsible for the company's returns. Where the company uses a registered agent, the agent's role under section 71A(8) of the Financial Services Act includes filing the returns and documents required under the Financial Services Act, the Income Tax Act or the Companies Act, passing on communications with the FSC, the MRA and the Registrar, AML/CFT measures and keeping the records (minutes, resolutions, transaction documents). That scope applies to Authorised Companies, and the Act text relied on here is the consolidated version as at 1 September 2026. If a service provider holds your records, make sure you know where they are and how quickly you can obtain them.

For routine filing, filing with the MRA online and corporate income tax return filing set out the practical steps that precede any review.

Common mistakes

• Treating the return as the end of the work. The evidence matters as much as the filing.
• Mixing private and business spending. It weakens every other deduction.
• Relying on a verbal explanation. An oral account from a former adviser carries little weight without documents.
• Claiming a relief without checking its conditions. A reduced rate or exemption depends on the facts staying true.
• Losing records when a provider or adviser changes. Retrieve your file at the handover.
• Ignoring status. A company managed from abroad should not assume its status without evidence.

If you want a second opinion on how well your company's file would stand up, you can send a request through the contact form and it will be passed to an FSC-licensed corporate service provider (Management Licence).