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Tax Planning & Structuring

Tax Efficiency, Lawfully and Sustainably Achieved

Mauritius's extensive Double Taxation Avoidance Agreement network, spanning 46 countries across Africa, Asia, and Europe, is one of the most powerful tools available for legitimate international tax planning. Aurevya's tax practice translates this network into real economic benefit.

Overview

Tax Planning Through the Mauritius Platform

Effective international tax structuring requires a sophisticated understanding of both Mauritius's domestic tax framework and the interaction of its DTAAs with the tax systems of multiple counterpart jurisdictions. Aurevya advises on the design of tax-efficient holding and operating structures, applying the DTAA network to reduce withholding taxes on dividends, interest, and royalties flowing through Mauritius.

We also advise on the impact of the OECD's Base Erosion and Profit Shifting (BEPS) framework, substance requirements, and transfer pricing considerations, ensuring that tax positions are not only correct today but fully defensible in the future. In a post-BEPS world, tax planning that lacks economic substance is not merely ineffective, it creates existential risks for the structures that depend on it.

Aurevya's approach is to design structures that are both tax-efficient and substantively robust, combining the real economic benefits available through the Mauritius platform with the governance, substance, and documentation standards that withstand scrutiny from any tax authority in any relevant jurisdiction.

46+
Double Taxation Agreements
Mauritius's treaty network covers key investment destinations across Africa, Asia, and Europe, providing unparalleled access for structuring cross-border income flows.
15% / 3%
Corporate Tax / Effective Rate
The standard 15% corporate rate with the 80% partial exemption regime for qualifying passive income, producing an effective rate as low as 3% on dividends, interest, and royalties.
BEPS
Compliant Structures
All Aurevya-designed structures are assessed for BEPS alignment, ensuring that the tax positions adopted are sustainable under evolving international standards.

What We Provide

Key Features of Our Tax & Structuring Service

DTAA Application Strategy
We analyse the client's investment and income flows to determine which of Mauritius's treaties are applicable and how to optimise the structure to maximise treaty benefits, including the selection of entity type, income characterisation, and holding structure design.
Withholding Tax Reduction
Mauritius's DTAAs reduce or eliminate withholding taxes on dividends, interest, and royalties paid from treaty partner jurisdictions to a Mauritius GBC, often from rates of 20–30% to single figures or zero. Identifying and realising these reductions is a core deliverable of the tax structuring service.
Holding Structure Design
We design holding structures that position Mauritius entities appropriately within a group, whether as direct holding entities, intermediate holding companies, or sub-holding vehicles, to achieve the optimal combination of treaty access, tax efficiency, and operational flexibility.
Transfer Pricing Compliance
Where intercompany transactions occur between related entities across jurisdictions, transfer pricing rules require that those transactions be priced on an arm's-length basis. We advise on transfer pricing policy design, documentation requirements, and the management of transfer pricing risk within multi-jurisdictional structures.
BEPS Alignment
The OECD's BEPS framework has reshaped the landscape of international tax planning. We advise clients on the substance requirements, principal purpose test implications, and country-by-country reporting obligations relevant to their structures, ensuring full BEPS alignment from inception.
Multi-Jurisdiction Planning
For groups with operations or investments in multiple jurisdictions, we coordinate the tax structuring advice across all relevant countries, ensuring that the Mauritius structure interacts optimally with the tax frameworks of each jurisdiction in which the group operates.

Process

How It Works

01
Tax Position Analysis
We conduct a comprehensive analysis of the client's current tax position, mapping existing income flows, withholding tax costs, and the tax attributes of each jurisdiction in which the group operates, to identify the full scope of structuring opportunity.
02
Structure Mapping
Based on the tax position analysis, we design the optimal holding and operating structure, identifying the appropriate entity types, ownership tiers, and jurisdiction sequence to achieve the client's tax efficiency objectives while satisfying substance and BEPS requirements.
03
DTAA Benefit Assessment
We provide a jurisdiction-by-jurisdiction analysis of the withholding tax benefits available under the applicable DTAAs, quantifying the tax savings achievable through the Mauritius structure and confirming that treaty conditions (including substance and principal purpose requirements) are met.
04
Structure Implementation
Following client approval of the proposed structure, Aurevya coordinates the implementation, incorporating the required entities, establishing banking, putting intercompany agreements in place, and ensuring that the governance and substance framework is in place from day one.
05
Ongoing Tax Review
Tax laws and treaty networks change. Aurevya provides periodic tax reviews, reassessing the structure against current law and treaty provisions, advising on any adjustments required to maintain optimality, and ensuring that the client's tax position remains both efficient and defensible over time.

Common Questions

Frequently Asked Questions

When income such as dividends, interest, or royalties flows from a source jurisdiction to a recipient in Mauritius, the source jurisdiction normally levies a withholding tax. Mauritius's DTAAs cap these withholding taxes at the rates specified in each treaty, often substantially lower than the domestic withholding tax rate of the source jurisdiction. For example, where a domestic withholding rate on dividends might be 20%, the applicable DTAA may cap it at 5% or 0% for a Mauritius GBC holding a qualifying ownership interest. The GBC must be a tax resident of Mauritius and must satisfy the treaty's conditions, particularly any limitation of benefits or principal purpose requirements, to claim these reduced rates.
The partial exemption regime allows a GBC to deduct 80% of certain categories of qualifying income from its chargeable income, effectively reducing the Mauritius corporate tax rate on those income streams from 15% to 3%. The categories of income eligible for the partial exemption include: foreign dividends; foreign-source interest; royalties; income from financial transactions with non-residents; and capital gains on disposal of securities. The partial exemption is not automatic, the GBC must meet specific conditions and elect to apply the exemption in its tax return. Aurevya's accounting and tax team manages this process as part of the annual tax compliance service.
The OECD's Base Erosion and Profit Shifting framework has introduced a range of measures that directly affect the design and operation of international tax structures. Most significantly for Mauritius: the Principal Purpose Test (PPT) in many updated DTAAs allows treaty benefits to be denied where one of the principal purposes of the arrangement was to obtain those benefits, requiring that structures have genuine commercial purposes beyond tax reduction; country-by-country reporting obligations apply to large multinational groups; and substance requirements have been significantly strengthened. Aurevya's tax practice designs structures that satisfy these requirements from inception, avoiding the risks associated with poorly substantiated treaty claims.
Transfer pricing rules require that transactions between related parties, intercompany loans, service agreements, IP licences, and management fee arrangements, be priced as if they had been conducted between independent parties dealing at arm's length. Where a Mauritius entity is part of a multi-jurisdictional group and engages in intercompany transactions, the pricing of those transactions must reflect arm's-length market rates. Failure to comply with transfer pricing rules can result in tax assessments, penalties, and double taxation in the jurisdictions involved. Aurevya advises on transfer pricing policy, assists with the preparation of transfer pricing documentation, and ensures that intercompany agreements accurately reflect the agreed arm's-length pricing methodology.
Mauritius is one of the most important jurisdictions globally for structuring investment into Africa. Its DTAA network covers key African investment destinations; its membership of COMESA, SADC, and the African Continental Free Trade Area provides market access benefits; and its bilateral investment treaties protect investments from political risk. A GBC used as an African investment holding company can benefit from reduced withholding taxes on dividends and capital gains from investee companies in treaty jurisdictions, as well as the legal protections afforded by the applicable bilateral investment treaties. Aurevya has significant experience designing African investment platforms through Mauritius and can advise on the optimal structure for any specific investment mandate.

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