Pillar Two in Mauritius: The rules are now here

Mauritius has taken another important step in the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Pillar Two framework with the publication of the Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026, gazetted on 8 August 2026. The regulations are deemed to have come into operation on 1 July 2025.

Turning policy into practice

The recently published QDMTT regulations are aligned with the OECD Global Anti-Base Erosion (GloBE) Model Rules and Commentary and provide guidance on the computation and administration of the Mauritian QDMTT. Among other matters, they address the determination of GloBE income or loss, adjusted covered taxes, excluded persons and transitional rules. 

Importantly, the regulations incorporate the Substance-Based Income Exclusion (SBIE), including both the payroll carve-out and tangible asset carve-out, consistent with the OECD framework. They also introduce the transitional Country-by-Country Reporting (CbCR) safe harbour, offering potential relief for eligible groups during the transition period.

With the regulations now in place, attention will inevitably turn to the practical aspects of compliance, including the anticipated release of the Mauritius QDMTT return and related administrative guidance.

We will continue to monitor developments closely and provide further updates and insights as the Mauritian Pillar Two framework evolves.

Stay tuned for more from PwC Mauritius.

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