Mauritius Double Tax Treaties: Complete Table of All 46 Agreements
Mauritius has 46 double taxation agreements (DTAs) in force. These treaties determine how income is taxed when it flows between Mauritius and another country, reducing or eliminating double taxation on dividends, interest, royalties and capital gains. For investors, fund managers and companies structuring through Mauritius, the withholding rates in these treaties are where any cross-border tax analysis begins.
This table lists every treaty currently in force, with the maximum withholding tax rates applicable in the source country. Data is from the Mauritius Revenue Authority.
All 46 treaties: withholding rates
| # | Country | Dividends | Interest | Royalties |
|---|---|---|---|---|
| 1 | Australia (partial) | – | – | – |
| 2 | Barbados | 5% | 5% | 5% |
| 3 | Belgium | 5-10% | 10% | Exempt |
| 4 | Botswana | 5-10% | 12% | 12.5% |
| 5 | Cabo Verde | 5% | 10% | 7.5% |
| 6 | China | 5% | 10% | 10% |
| 7 | Congo (Republic) | 0-5% | 5% | Exempt |
| 8 | Croatia | Exempt | Exempt | Exempt |
| 9 | Cyprus | Exempt | Exempt | Exempt |
| 10 | Egypt | 5-10% | 10% | 12% |
| 11 | Estonia | 0-7% | 0-7% | 0-5% |
| 12 | Eswatini | 7.5% | 5% | 7.5% |
| 13 | France | 5-15% | Domestic rate | 15% |
| 14 | Germany | 5-15% | Exempt | 10% |
| 15 | Ghana | 7% | 7% | 8% |
| 16 | Guernsey | Exempt | Exempt | Exempt |
| 17 | Hong Kong | 0-5% | 5% | 5% |
| 18 | India | 5-15% | 7.5% | 15% |
| 19 | Italy | 5-15% | Domestic rate | 15% |
| 20 | Jersey | Exempt | Exempt | Exempt |
| 21 | Kuwait | Exempt | Exempt | 10% |
| 22 | Lesotho | 10% | 10% | 10% |
| 23 | Luxembourg | 5-10% | Exempt | Exempt |
| 24 | Madagascar | 5-10% | 10% | 5% |
| 25 | Malaysia | 5-15% | 15% | 15% |
| 26 | Malta | Exempt | Exempt | Exempt |
| 27 | Monaco | Exempt | Exempt | Exempt |
| 28 | Mozambique | 8-15% | 8% | 5% |
| 29 | Namibia | 5-10% | 10% | 5% |
| 30 | Nepal | 5-15% | 10-15% | 15% |
| 31 | Oman | Exempt | Exempt | Exempt |
| 32 | Pakistan | 10% | 10% | 12.5% |
| 33 | Bangladesh | 10% | 10% | 10% |
| 34 | Qatar | Exempt | Exempt | 5% |
| 35 | Rwanda | 10% | 10% | 10% |
| 36 | Seychelles | Exempt | Exempt | Exempt |
| 37 | Singapore | Exempt | Exempt | Exempt |
| 38 | South Africa | 5-10% | 10% | 5% |
| 39 | Sri Lanka | 10-15% | 10% | 10% |
| 40 | Sweden | 0-15% | Exempt | Exempt |
| 41 | Thailand | 10% | 10-15% | 5-15% |
| 42 | Tunisia | Exempt | 2.5% | 2.5% |
| 43 | Uganda | 10% | 10% | 10% |
| 44 | United Arab Emirates | Exempt | Exempt | Exempt |
| 45 | United Kingdom | 0-15% | Domestic rate | 15% |
| 46 | Zimbabwe | 10-20% | 10% | 15% |
Notes on the table:
- Where two rates are shown (e.g. 5-15%), the lower rate typically applies when the beneficial owner holds a qualifying percentage of the paying company’s capital (usually 10-25%). The higher rate applies in all other cases.
- “Domestic rate” means the treaty does not cap the rate below the source country’s domestic withholding tax rate.
- “Exempt” means the source country cannot withhold tax on that income category; it is taxable only in the residence country (Mauritius).
- Interest exemptions in most treaties extend to interest paid to or received by a Contracting State, its central bank, or bona fide banking institutions.
- The Australia treaty is partial and does not cover dividends, interest or royalties in the standard sense.
Use the Mauritius tax calculator to estimate your own tax liability.
Treaties with the lowest withholding rates
Twelve treaty partners offer full or near-full exemption on dividends, interest and royalties:
- Full exemption (all three): Croatia, Cyprus, Guernsey, Jersey, Malta, Monaco, Oman, Seychelles, Singapore, UAE
- Near-full exemption: Kuwait (exempt on dividends and interest, 10% on royalties), Qatar (exempt on dividends and interest, 5% on royalties), Tunisia (exempt on dividends, 2.5% on interest and royalties)
These treaties are most commonly used for holding structures, treasury operations and IP licensing arrangements where the counterparty is in one of these jurisdictions.
Key African treaties
Mauritius is the most common holding jurisdiction for investment into Africa, and the African treaty network is a major reason. The most frequently used African treaties by withholding rates:
| Country | Dividends | Interest | Royalties |
|---|---|---|---|
| Congo (Republic) | 0-5% | 5% | Exempt |
| Mozambique | 8-15% | 8% | 5% |
| Namibia | 5-10% | 10% | 5% |
| South Africa | 5-10% | 10% | 5% |
| Madagascar | 5-10% | 10% | 5% |
| Ghana | 7% | 7% | 8% |
| Rwanda | 10% | 10% | 10% |
| Uganda | 10% | 10% | 10% |
Note: the treaties with Senegal and Zambia have been terminated. Kenya, Nigeria, Morocco and Angola have signed treaties awaiting ratification.
The India treaty
The India-Mauritius DTA is historically the most significant. It was amended by protocol in 2016, and the key change was the introduction of source-country taxation on capital gains from the disposal of shares in Indian companies. Before the amendment, such gains were taxable only in Mauritius (where there is no capital gains tax), making Mauritius the dominant route for portfolio investment into India.
Under the current treaty:
- Dividends: 5% (if the beneficial owner holds at least 10% of capital) or 15% (all other cases)
- Interest: 7.5%
- Royalties: 15%
- Capital gains on shares: taxable in India at Indian domestic rates (since April 2017)
The treaty remains beneficial for dividend flows and interest income but no longer provides the capital gains advantage that defined Mauritius-India investment for decades.
Treaties under negotiation or awaiting ratification
As of 2026, the pipeline includes:
- Awaiting ratification (7): Angola, Comoros, Gabon, Kenya, Morocco, Nigeria, Russia
- Awaiting signature (7): Botswana (new treaty), Curaçao, Czech Republic, Gibraltar, Guyana, Malawi, The Gambia
- Under negotiation (19): Algeria, Burkina Faso, Canada, Côte d’Ivoire, Greece, Iran, Mali, Montenegro, Portugal, Saudi Arabia, Senegal (new), Spain, St. Kitts and Nevis, Sudan, Tanzania, Turkey, Vietnam, Yemen, Zambia (new)
The Kenya and Nigeria treaties are the most commercially significant in the pipeline. Once in force, they will strengthen Mauritius’s position as the holding jurisdiction of choice for East and West African investments.
How to use this table
The withholding rates in the table are the maximum rates the source country can charge under the treaty. To benefit from these reduced rates, a Mauritius company must:
- Be tax resident in Mauritius (hold a valid Tax Residence Certificate from the MRA)
- Be the beneficial owner of the income (not a conduit or agent)
- Pass the Limitation on Benefits and Principal Purpose Tests under BEPS
- Meet the substance requirements for GBCs
Without a TRC and genuine substance, treaty benefits can be denied by the source country’s tax authority.
For the broader tax framework, see the Mauritius tax guide and the tax system guide for expats. For changes introduced in 2025, see Finance Act 2025 tax changes. Subscribe to the newsletter for updates when new treaties enter into force.
