The Revenue Tribunal Rules 2026, made under Section 15 the Revenue Tribunal Act 2025, introduce a clearer and more structured procedural framework for appeals before the Revenue Tribunal (the “Tribunal”) in Mauritius. These rules apply to appeals relating to income tax, VAT, customs, excise, gambling and other revenue matters falling within the scope of legislation listed under the Act’s Schedule.
Here are the main practical highlights:
Initiation of appeals
Appeals must be lodged through a formal Notice of Appeal, either physically (in triplicate) or electronically, in the prescribed form. The grounds of appeal set out at this stage are critical, as no new grounds may be introduced later unless permitted by the Tribunal.
Statement of Case and timelines
For most tax determinations issued by the Director-General, appellants are required to file a detailed Statement of Case within 28 days of lodging the appeal. This obligation does not apply to individuals not in business, or to smaller enterprises with declared gross income below MUR 10 million. Clear statutory timelines now apply to both parties, promoting procedural discipline.
Early disclosure and witness evidence
Where applicable, parties must exchange Statements of Case, Replies and witness statements within successive statutory periods of 28 days. Witness statements stand in place of examination-in-chief, with witnesses attending hearings mainly for confirmation and cross-examination. As a result, evidential material is placed on record earlier in the process, with hearings focusing on confirmation and testing of that evidence.
Case management and flexibility
The Chairperson or Vice-Chairperson has broad case-management powers, including extending deadlines in exceptional circumstances and directing additional filings in complex or high-value cases. Preliminary hearings must be scheduled within 120 days of lodging an appeal
Remote hearings and document-based decisions
The Tribunal may conduct hearings remotely via virtual means where this is directed to ensure a fair hearing, and, in certain cases, determine matters exclusively on the basis of documentary evidence. Where hearings are conducted remotely, no recording is permitted without written consent, and the official record is limited to the Tribunal’s minutes.
Notification of legal representation
The Rules formalise the obligation for parties intending to be represented by counsel or an attorney to notify the Tribunal at the first preliminary hearing, including details of availability for the indicative hearing period. Any subsequent change or appointment must be notified within seven working days. Failure to comply, without reasonable cause, allows the Tribunal to proceed and may result in adjournments being refused on grounds of counsel unavailability.
Appeals involving similar issues
The Rules empower the Tribunal to consolidate appeals that raise the same or substantially similar issues of fact or law, either on its own initiative or upon application by a party. Where parties consent, consolidation may be ordered administratively; where there is no consent, the Tribunal will hear arguments and determine whether consolidation is appropriate. This mechanism is intended to promote procedural efficiency and consistency in the determination of related appeals.
Withdrawal of appeals
The Rules allow an appellant to withdraw an appeal at any time prior to the Tribunal issuing its decision. Withdrawal may be effected either by a written notice duly signed by the appellant and copied to the respondent, or by way of a formal motion made before the Tribunal.
Mediation and settlement
The Rules formally integrate mediation into the Tribunal process as a distinct and structured stage of dispute resolution. Mediation proceedings are conducted on an informal and confidential basis, with the objective of enabling parties to resolve the appeal by agreement or, where full resolution is not possible, to narrow the issues in dispute. Any settlement reached may be recorded by the Tribunal and given formal effect. Where mediation does not result in settlement, the matter is referred back to the Chairperson, and any issues agreed or no longer in dispute may be captured in a written memorandum. That memorandum forms part of the record and is binding on the parties, ensuring that the subsequent hearing is confined to the remaining disputed issues.
Practical compliance points
- Appeals must be filed by 14:30 on the final day of the statutory deadline
- Documentary evidence not disclosed during the objection stage may be rejected unless justified
- Clerical errors may be rectified within 7 days, with appeal timelines running from the rectified decision
Overall impact
The Revenue Tribunal Rules 2026 mark a shift towards a more structured, transparent and efficient dispute-resolution process, with stronger emphasis on early disclosure, procedural discipline and alternative dispute resolution.
These changes are relevant to taxpayers, businesses and other stakeholders involved in revenue disputes before the Tribunal.
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