• Foreign source dividend derived by a company provided that it has not been allowed as a deduction in the country of source;
• Interest derived by a company;
• Income derived by a collective investment scheme (“CIS”); closed end fund, CIS Manager, CIS administrator; investment adviser, investment dealer or asset manager;
• Income derived by companies engaged in leasing of ships, aircrafts, locomotives and trains including rails leasing;
• Income derived by a company from reinsurance and reinsurance brokering activities;
• Income derived by a company from leasing or provision of international fibre capacity;
• Income derived by a company from the sale, financing arrangement, asset management of aircraft and its spare parts and aviation advisory services related thereto;
• §interest derived by a person from money lent through Peer-to-Peer Lending platform;
• profit attributable to a permanent establishment which a resident company has in a foreign country;
• income derived by companies holding a Robotic and Artificial Intelligence Enabled Advisory Services Licence
• Income derived from the sale of money market instruments or debt instruments for licensed Closed-End Funds.
• Income derived by companies holding as Payment Intermediary Services (“PIS”) licence .

Dividend Income

Foreign-source dividend income may be eligible for partial exemption under simplified conditions. To qualify for an 80% exemption on such income, companies must meet the following requirements:

Compliance with Filing Obligations
The company must comply with all its filing obligations under the Companies Act or the Financial Services Act. This requirement ensures that the company is meeting its legal obligations and is operating transparently.

Adequate Resources for Share Participations
The company must have adequate resources available for holding and managing share participations. This requirement ensures that the company has the necessary financial resources and expertise to manage its investments effectively. This requirement can be met at the board of director level.
 

Other Income

To qualify for partial exemption on specified categories of income other than dividend in Mauritius, a company must satisfy the following three key conditions:

1. The company must carry out its core income generating activities (CIGA) in Mauritius.
   CIGA refers to essential activities that are central to a company's main operations, generate its income, are strategic in nature, and focus on improving customer value as the profit-center of the business. The Income Tax (Amendment No.2) Regulations 2019 establish the eligibility requirements that GBCs must meet in order to take advantage of the Partial Exemption Regime.
    
2. The company must employ an adequate number of suitably qualified persons to conduct its CIGA, either directly or indirectly.
   The company must have enough qualified staff to carry out their core business activities, and these employees should have the necessary knowledge and skills for their roles. The number of staff must be appropriate for the company's level of activities.
    

   Outsourcing of core income generating activities is allowed but should be done within Mauritius. A service provider in Mauritius may be hired for core income generating activities to benefit from partial exemption. Imara Trust Company (Mauritius) Limited, as a service provider  can provide assistance with outsourcing core income generating activities within Mauritius, ensuring that there is adequate supervision of the outsourced activities and no double or multiple counting if the services are provided to multiple companies. This can help companies benefit from the partial exemption on income.

    

3. The company must incur a minimum expenditure proportionate to its level of activities.
   Expenses related to carrying out the CIGA must be reasonable and appropriate based on the nature and level of activities. The company must maintain and retain records to show that adequate resources were utilized and expenses were incurred.
    

   The requirement that the core income-generating activities be carried out in or from Mauritius only applies to a holder of a Global Business License if the holder claims or intends to claim for partial exemption. Companies that have claimed the 80% partial exemption are not allowed to claim actual foreign tax credit on their foreign-source income.