Mauritius: Assessment review committee ruling on timing of acquisition for investment tax credit purposes
Acquisition occurs only when plan and machinery are actually used in business.
The Assessment Review Committee (ARC) overruled the disallowance by the Mauritius Revenue Authority (MRA) of the taxpayer’s claim for investment tax credits on certain plant and machinery (P&M).
ITC is granted as a credit against income tax liability in the year of acquisition and the two subsequent income years, provided the taxpayer incurred capital expenditures on new P&M from July 1, 2016, to June 30, 2020. The MRA disallowed the taxpayer’s ITC claim, arguing that the taxpayer acquired the P&M before June 30, 2016, as parts of the P&M were imported prior to that date. However, the ARC ruled that the shipment of P&M parts prior to July 1, 2016, did not constitute an acquisition for ITC purposes. Rather, ITC can only be claimed when the P&M is fully assembled, commissioned, and brought into actual use in the business, which occurred after July 1, 2016.
Read an April 2025 report prepared by the KPMG member firm in Mauritius