Partial Exemption Regime

The Income Tax Act Regulations 1996 will be amended to include:

  • the detailed substance requirements that must be met for a taxpayer to enjoy the partial exemption benefit; and
  • the conditions that must be satisfied where a company outsources its core income generating activities, namely:
    • demonstrate adequate monitoring of the outsourced activities
    • the outsourced activities must be conducted in Mauritius; and
    • the economic substance of service providers must not be counted multiple times by different companies when evidencing their own substance in Mauritius.

Broadening of Partial Exemption Regime

The partial exemption regime will be extended to cover companies engaged in:

  • leasing and provision of international fibre capacity
  • reinsurance and brokering of reinsurance services
  • sale, financing arrangement and asset management of aircraft and its spare parts, including aviation related advisory services.

KPMG Views

Extending the partial exemption is welcomed. However, more could have been done with a view of encouraging multinational enterprises to conduct more functions from Mauritius.


The above information has been extracted from the budget speech delivered by The Honourable Pravind Kumar Jugnauth, Prime Minister, Minister of Home Affairs, External Communications and National Development Unit and Minister of Finance and Economic Development, to the National Assembly, on 10 June 2019.

The Budget proposals may be amended significantly before enactment. The content of this summary is intended to provide a general guide to the subject matter and should not be regarded as a basis for ascertaining liability to tax or determining investment strategy in specific circumstances. In such cases specialist advice should be taken.