Mauritius: Assessment Review Committee upholds arm's length principle for domestic interest-free loans

Affirmed tax authority’s imputation of deemed interest

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September 16, 2025

The Mauritius Assessment Review Committee ruled that interest-free loans between related resident companies must adhere to the arm's length principle, affirming the Mauritius Revenue Authority's (MRA) use of section 75 of the Income Tax Act to impute deemed interest.

The committee’s decision in Manipal Academic Services International Ltd v. Director General emphasized section 75's applicability to both domestic and international transaction and highlighted the absence of a formal loan agreement and market-based terms.


For more information, contact a KPMG tax professional in Mauritius:

Wasoudeo Balloo | wballoo@kpmg.mu

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