دليل هجرة الاستثمار في موريشيوس: المزايا الضريبية وحماية الأصول

Mauritius has built one of the most mature investment migration ecosystems in the Indian Ocean. Sitting between Africa and Asia, the island combines a bilingual common-law/civil-law legal system, a 15% corporate tax rate, a fully active international financial centre, and 45 double taxation treaties. For investors, entrepreneurs and high-net-worth families looking at 2026 and beyond, Mauritius offers real residence-by-investment options, targeted asset-protection vehicles, and a territorial personal tax system — all significantly reshaped by the قانون المالية 2025.

This guide explains how the updated rules work in practice: which residence routes are still open, the new dual-track Investor Occupation Permit (USD $50,000 vs USD $100,000), the longer 5-year path to the 20-year Permanent Residence Permit, the Section 9(3) fast-track naturalisation framework, Mauritius trust and foundation law, and the tax, banking and crypto rules that matter for relocation planning.

Residence by investment in Mauritius

Mauritius does not run a “Golden Visa” in the Portuguese or Spanish sense. What it offers is a set of statutory permits administered by the مجلس التنمية الاقتصادية through the NELS online portal, with the Passport and Immigration Office (PIO) handling the actual residence cards. Two routes dominate planning conversations: the property route and the Investor Occupation Permit.

The USD $375,000 property route

A foreign buyer who invests at least USD $375,000 in an EDB-approved development qualifies for a Residence Permit tied to ownership of the property. The permit covers the investor, spouse, and dependent children. It is important to frame this correctly: it is not a 20-year Permanent Residence Permit — it lasts only as long as the investor holds the qualifying property. Selling the property ends the right of residence.

Eligible schemes include the مخطط تطوير العقارات, مخطط المدينة الذكية, G+2 apartment developments (with a MUR 6 million floor), and the Invest Hotel Scheme. Integrated Resort Scheme (IRS) and Real Estate Scheme (RES) properties are only available on the resale market — no new IRS or RES projects are being approved. From 1 يوليو، 2026, registration duty and land transfer tax on non-citizen purchases under EDB schemes each double from 5% to 10%, bringing total transaction taxes to 20% of price — a meaningful deadline for anyone currently planning a purchase.

The Finance Act 2025 also repealed the old USD $500,000 / 1.25-acre “outside-scheme” route for non-residents. Foreign buyers who are not already resident in Mauritius can now only acquire residential property inside an EDB-approved scheme. A further post-purchase rule applies from December 13, 2024: 85% of the purchase price must settle in Mauritian rupees, converted from incoming hard currency.

The Investor Occupation Permit — now a dual-track system

The Investor OP is a 10-year renewable work-and-residence permit issued to foreign nationals running a Mauritius company. The Finance Act 2025 split it into two tracks:

The Year 5 review is the single most important enforcement mechanism added in 2025. An investor who has not met the declared turnover threshold, or whose business no longer has genuine substance, can have the permit revoked — which in turn breaks the clock toward a Permanent Residence Permit. For this reason we always advise documenting real operating activity from month one rather than treating the OP as a passive residency vehicle.

Other Occupation Permit categories

Beyond the investor route, Mauritius offers the Professional OP (foreign employee earning above a set monthly threshold), the Self-Employed OP (Finance Act 2025 raised the initial transfer to USD $50,000), and the Retired Residence Permit (non-citizens aged 50+ transferring at least USD $2,000 per month). For remote workers and short-term relocators, the Premium Travel Visa is free (a new USD $50 processing fee may apply from December 2025), runs for one year renewable, requires USD $1,500 per month of foreign-sourced income per adult plus USD $500 per dependent child under 24, and covers 114+ eligible countries. It does not lead to permanent residence.

From Occupation Permit to Permanent Residence

The Permanent Residence Permit (PRP) is a 20-year renewable permit. Until 2024 it was available after 3 years on an OP; the Finance Act 2025 raised this to 5 years of continuous OP status with compliant activity. There is also a direct PRP route for investors who commit USD $375,000+ in a business generating at least 5 local jobs. Applications must be submitted within 6 months of satisfying the criteria, and a medical certificate is now required.

Citizenship: the naturalisation framework

Residence-by-investment does not itself grant Mauritius citizenship — the two are separate legal processes. Ordinary naturalisation under the Mauritius Citizenship Act requires, for non-Commonwealth applicants, 5 years of residence within the preceding 7 years plus 12 continuous months immediately before application. Commonwealth citizens need 5 continuous years. Applicants must demonstrate good character, adequate knowledge of English or French, and intention to reside.

Section 9(3) of the Citizenship Act creates a discretionary fast-track: a minimum USD $500,000 investment plus 2 years of continuous residence. It is important to understand what this is — and what it isn’t. It is not a “golden passport” programme with guaranteed approval. Final approval rests with the Prime Minister’s Office and is discretionary. Genuine physical residence is required, the investment must have economic substance, and processing typically runs 6–18 months after the 2-year residence clock has been met.

Taxation of individuals and companies

Personal income tax — the new three-band system

Effective from the 2025/26 income year, the Finance Act 2025 replaced the previous 9-band progressive structure with a simplified three-band system:

The 0% band was widened from Rs 390,000 to Rs 500,000 as of July 1, 2025. Two additional layers now sit on top of the 20% ceiling: a Fair Share Contribution (FSC) of 15% on leviable income above Rs 12 million, rising to 20% above Rs 24 million, in force from July 2025 through June 2028. Global Business Licence (GBL) holders are explicitly exempt from FSC. A youth exemption fully exempts individuals aged 18–28 earning Rs 1 million or less.

Mauritius retains a territorial / remittance basis for individuals: foreign-source income is taxed only if remitted to Mauritius. Note however the Supreme Court’s Dilloo decision (2024), which clarified that even non-residents can trigger tax obligations when remitting funds into Mauritius. Zero-rate headline items remain intact: no capital gains tax, no inheritance or estate tax, no wealth tax, no gift tax, and no withholding tax on dividends paid to non-residents. Withholding tax on interest and royalties paid to non-residents is 15%, reducible under treaty.

Corporate tax and the Global Business regime

The standard corporate tax rate is 15%. Through the Partial Exemption Regime (PER), 80% of qualifying foreign-source income (dividends, interest, certain royalties) can be exempted, producing an effective rate of 3% for eligible Global Business Companies. To claim PER, a GBC must satisfy substance tests: Core Income Generating Activities (CIGAs) carried out in Mauritius, adequate qualified staff, and proportionate expenditure. Outsourcing to Mauritius-based licensed providers is permitted with appropriate oversight.

New corporate-level taxes added by Finance Act 2025: a 5% corporate FSC (reduced to 2% for companies taxed at the 3% effective rate) on chargeable income above Rs 24 million from July 2025 to June 2028; a Qualified Domestic Minimum Top-up Tax (QDMTT) of 15% for multinational groups with global revenue above EUR 750 million (Pillar 2 implementation, effective July 2025); and an Alternative Minimum Tax of 10% for hotels, insurance, financial services, real estate and telecoms. GBL entities remain outside FSC.

VAT stays at 15%. From January 1, 2026, VAT applies to digital services supplied from abroad to Mauritius customers. The VAT registration threshold was lowered from Rs 6 million to Rs 3 million in October 2025. CFC rules have been in force since July 2020, with safe harbours for low-profit or adequately-taxed foreign subsidiaries.

شبكة اتفاقيات تجنب الازدواج الضريبي

Mauritius currently has 45 double taxation treaties in force (per the Mauritius Revenue Authority), with another 7 awaiting ratification (including Kenya, Nigeria, Morocco, Russia and Angola). Key partners include India, China, the United Kingdom, France, Germany, Singapore, the UAE, South Africa, Hong Kong and Luxembourg. Three treaties have been terminated (Nepal, Senegal, Zambia). The treaty network, combined with the 3% effective GBC rate, is the traditional reason Mauritius is used as a holding-company hub for investment into Africa and South Asia.

Asset protection: trusts, foundations, and GBCs

Mauritius operates a hybrid legal system: French civil law (the Code Civil) governs private law, property and succession, while British common law governs commercial, corporate, trust and procedural matters. Final appeals go to the Judicial Committee of the Privy Council in London. This dual heritage is why Mauritius trust and foundation law feels familiar to both Francophone European families and Anglo-American corporate clients.

Mauritius trusts — Trusts Act 2001

القسم 9 من قانون الائتمانات لعام 2001 fixes the maximum trust duration at 99 سنة from the date the trust comes into existence. (This corrects a figure often quoted as 120 years — the statute is explicit.) Charitable purpose trusts may be perpetual. Non-charitable purpose trusts, and any trust holding Mauritius real estate, are capped at 25 years — a public-policy limit designed to prevent long-term “dead hand” control of domestic land.

Available forms include discretionary trusts, fixed/life interest trusts, charitable and non-charitable purpose trusts, protective/spendthrift trusts, employee benefit trusts and foreign trusts. Registration is not compulsory for most trusts — a trust is created by written deed with no public filing. At least one Financial Services Commission (FSC)-licensed qualified trustee is mandatory, with a maximum of four trustees. Purpose trusts must appoint an FSC-approved Enforcer. Beneficial owner information is not on a public register and is disclosed only to competent authorities or under court order.

Mauritius foundations — Foundations Act 2012

Foundations have been available since July 1, 2012. A Mauritius foundation is a separate legal entity — a hybrid between a trust and a company — governed by a Council of at least one member, with an FSC-licensed management company acting as secretary. Annual registration fees are MUR 9,000. Critically for asset-protection planning, foundation assets cannot be set aside on the basis of forced heirship rules in the founder’s domicile, which makes the vehicle particularly attractive to clients from civil-law jurisdictions with forced-heirship regimes.

شركات الأعمال العالمية (GBCs)

A Mauritius GBC is the workhorse of the offshore sector. Formation requirements: minimum two resident directors (ordinarily resident in Mauritius), no minimum share capital (USD $1 is technically valid), shares in any currency except MUR, a physical registered office in Mauritius via a licensed Management Company, principal bank account in Mauritius, and a minimum of two board meetings per year held in Mauritius. Beneficial owners holding 20% or more of voting rights must be declared; Finance Act 2025 requires written UBO declarations from all companies by June 30, 2026, with 7-year record-keeping.

Timelines and fees: Registrar of Companies incorporation takes 2–5 business days; FSC licensing for a GBC takes 4–8 weeks; total end-to-end is typically 4–8 weeks from completed KYC. The annual ROC fee is MUR 18,000 and the FSC annual licence fee is USD $1,950, payable by June 30 — from July 1, 2025, the FSC no longer accepts late renewals past this deadline. Total annual compliance costs realistically run USD $9,000–$20,000+ covering FSC renewal, registered office and secretarial services, nominee directors where used (approximately USD $1,500–$4,000 per director per year), accounting, audit, tax return preparation, and FATCA/CRS reporting.

Banking, crypto and compliance

القطاع المصرفي

Mauritius has a well-capitalised banking sector. Major banks include MCB Group, State Bank of Mauritius, Absa Bank Mauritius, AfrAsia Bank, Bank One, and HSBC Mauritius. The IMF’s 2025 Article IV assessment confirmed the sector remains resilient, with an average capital adequacy ratio of roughly 20–21% and a liquidity coverage ratio near 299% at December 2024. Non-resident account opening is available either in person or through licensed intermediaries for high-net-worth clients. Standard onboarding documents include passport, proof of residential address, bank reference letter, and source-of-funds evidence. Processing is typically around one week for standard cases, longer for complex structures. Minimum deposits vary by bank — standard accounts sit in the MUR 1,000–5,000 range, while non-resident private banking generally starts around USD $100,000.

Cryptocurrency and virtual assets — the VAITOS regime

استخدم Virtual Asset and Initial Token Offering Services (VAITOS) Act came into force on February 7, 2022, and remains the primary framework. The Finance (Miscellaneous Provisions) Act 2024 reclassified virtual assets as “securities” for tax purposes, which means disposal gains on crypto are tax-exempt as of July 1, 2024. (This is a material change from earlier guides that treated crypto gains as income.) Trading and mining income remain taxed as business income under the normal 0–20% bands; foreign-source crypto income is only taxable if remitted.

VASP licensing runs across five classes issued by the FSC: Class M (broker-dealer, MUR 2M capital), Class O (wallet services), Class R (custodian, MUR 5M capital), Class I (advisory), and Class S (marketplace, MUR 6.5M capital). A physical Mauritius office is required. Application fees run USD $1,000–$3,000 with annual licence fees of USD $1,900–$5,000; realistic Year 1 total cost for a fully-staffed VASP runs USD $165,000–$311,000+. Approval timelines are 4–6 months to in-principle approval, with 9–14 months to full licensing not uncommon. March 2025 amendments introduced mandatory automated transaction monitoring and real-time reporting of cross-border transfers. In December 2025 Mauritius signed the OECD Crypto-Asset Reporting Framework (CARF) Multilateral Competent Authority Agreement, with the first data exchange expected in 2027.

FATF status and international transparency

Mauritius is not on any FATF grey or black list as of April 2026, and was removed from the grey list in October 2021. The February 2026 FATF Plenary identified 23 jurisdictions on the grey list; Mauritius was not among them. Mauritius participates fully in the Common Reporting Standard (CRS) with automatic exchange of information agreements covering 100+ jurisdictions. UBO registers are non-public and accessible only to competent authorities or under court order. Full record-keeping obligations run to 7 years.

How Vardanyan & Partners assists

Vardanyan & Partners is an Armenian-based international law firm advising clients on cross-border residence, corporate structures, and tax planning. Our Mauritius practice typically coordinates with Mauritius-based licensed Management Companies and works alongside our Armenian legal team for clients pursuing multi-jurisdictional strategies — for example, combining an Armenian الشركة المشغلة with a Mauritius GBC for holding purposes, or layering Armenian residence-by-investment with a Mauritius trust for asset protection. If you are weighing Mauritius against other jurisdictions, we can help you benchmark the options objectively — including against Armenian citizenship planning routes and broader Armenian tax structuring.

الأسئلة المتكررة

This guide reflects the Mauritius legal and tax framework as of April 2026, incorporating the Finance Act 2025 and regulatory updates in force. Rules and thresholds change — please verify current figures with your advisor before acting.