Mauritius: Eligibility to claim partial exemption on interest income (Supreme Court decision)

Decision of the Supreme Court regarding partial exemption regime on interest income.

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February 18, 2025

The Supreme Court of Mauritius held in favor of a taxpayer producing electricity, granting them the 80% tax partial exemption regime (PER) on interest income earned from deposits with its sister company.

This decision overturned prior rulings of the Mauritius Revenue Authority and the Assessment Review Committee, which denied the exemption on the grounds that the interest income was unrelated to core income-generating activities. The court emphasized that for eligibility, a company must carry out core income-generating activities in Mauritius, employ an adequate number of qualified persons, and incur a minimum expenditure proportionate to its level of activities.

Read a February 2025 report prepared by the KPMG member firm in Mauritius

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