In its cabinet meeting on 30 January 2026, the Government of Mauritius agreed to the promulgation of the Income Tax (Amendment) Regulations 2026. These legislative changes significantly broadened the scope of Mauritius corporate tax Partial Exemption Regime (PER), commonly referred to as the 80 % partial exemption regime. These changes form part of a broader strategy to position Mauritius as a competitive jurisdiction for innovation, financial technology (FinTech), digital services, and emerging digital assets.
Background
Under Mauritius’s Income Tax Act, resident and global business companies have historically been eligible for an 80 % exemption on certain types of foreign‑sourced income, subject to satisfying prescribed substance requirements in Mauritius. The regime is intended to foster genuine economic activity in the jurisdiction while maintaining international competitiveness.
Extension of the Partial Exemption Regime to FinTech and Digital Licence Companies
Recent amendments introduced through the Finance (Miscellaneous Provisions) Act 2024 and subsequently affirmed in the Finance Act 2025 extend the 80 % partial exemption regime to companies holding specific licences issued by the Financial Services Commission (FSC):
- Payment Intermediary Services (PIS) Licence holders: Companies licensed to carry on payment intermediary services will benefit from the 80 % exemption on income derived from their qualifying activities, provided they satisfy the substance conditions in Mauritius.
- Robotic and Artificial Intelligence Enabled Advisory Services Licence holders: Companies licensed to provide advisory services enabled by robotics and artificial intelligence are now eligible for the 80 % exemption on income related to those licensed activities, subject to the same substance requirements.
- Virtual Asset Service Provider (VASP): Companies licensed as VASP are now eligible for the 80 % exemption on income related to those licensed activities, subject to the same substance requirements.
These extensions explicitly recognise digital and FinTech business models that did not previously fall within the traditional PER framework, reflecting Mauritius’s commitment to encouraging technology‑driven financial services.
Substance Requirements
To qualify for the exemption, companies must meet the core income‑generating activities (CIGA) and substance conditions set out in the relevant Income Tax Regulations. As required by the cabinet decision dated 30 January 2026, a company must carry out its CIGA in Mauritius, with the specific activities for each licence specified in the Income Tax (Amendment) Regulations 2026. These typically include conducting key decision‑making and operational activities in Mauritius, employing an adequate number of qualified staff locally, and incurring appropriate levels of expenditure in Mauritius relative to the level of income.
Implications for Investors and FinTech Businesses
The extension of the 80 % partial exemption regime presents several important opportunities and considerations:
It provides tax efficiency for FinTech and digital licence holders operating through Mauritius, making the jurisdiction more attractive for digital financial services and related business models.
It supports the development of local substance and economic activity, aligning with international standards while preserving tax competitiveness.
Companies planning to benefit from the regime should ensure full compliance with Mauritius substance requirements to avoid challenges from the Mauritius Revenue Authority (MRA).
Next Steps
Businesses considering establishing or expanding FinTech and digital services operations in Mauritius should engage in early planning for regulatory licensing and compliance to maximise the benefits of the expanded PER. Tax structuring should incorporate analysis of economic substance, licencing pathways, and long‑term operational footprint in Mauritius.
If you are considering establishing or expanding FinTech, digital services, artificial intelligence or virtual asset operations in Mauritius, our team can assist with tax structuring, regulatory licensing, substance requirements and ongoing compliance to help you maximise the benefits of the expanded partial exemption regime. Contact us today.
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