CHAPTER 1 - DIRECT TAXES

Under the Act, a company is liable to corporate tax on its chargeable income. Chargeable income is calculated as follows:

Chargeable Income = Gross Income less Allowable Deductions

Gross income includes:
(i) income from business;
(ii) income from property;
(iii) foreign dividends; and
(iv) interest and any other income.

Allowable deductions is relatively broad based and encompasses the following:
(i) Expenditure incurred in the production of income;
(ii) Expenditure incurred on interest in the production of income;
(iii) Accumulated losses from previous years
(iv) Bad and irrevocable losses
(v) Specific contributions and pensions
(vi) Annual and investment allowances

1. Name of Tax and Levied in Terms of Which (Name, Number and Year)

Corporate Tax, Income Tax Act 1995, Act No 16. of 1995 (hereinafter referred to as "the Act"

2. Department Responsible for Administration

(i) Income Tax Department; and
(ii) Large Taxpayers Department (for companies with turnover exceeding Rs 200 million)

3. Definition and Classification

The term "company" as defined in the Act:

(a) means a body corporate, other than a local authority, incorporated in Mauritius or elsewhere; and (b) includes a non-resident société, a trust or a trustee of a unit trust scheme; but
(c) does not include a Land Area Management Unit;

"Regulations" means "Income Tax Regulations 1996"

Land Area Mangement Unit is a Unit constituted by planters and metayers with the objective of improving their economic performance in the cultivation of cane and other crops

4. Basis of Taxation

4.1 Source-based or residence based

The Mauritian tax system is both residence based and source based.

4.2 If source, define:

4.2.1 Actual source

Applies to non-residents generating gross income in Mauritius.

4.2.2 Deemed source

None

4.3 If residence, define:

4.3.1 Define resident

S 73

- a company which :

(i) is incorporated in Mauritius; or
(ii) has its central management and control in Mauritius;

- a société which:

(i) has its seat or siège in Mauritius; and
(ii) has at least one associate or associé or gérant resident in Mauritius;

- a trust, means a trust -

(i) which is administered in Mauritius and a majority of the trustees are resident in Mauritius; or
(ii) where the settlor of the trust was resident in Mauritius at the time the instrument creating the trust was executed;

- any other association or body of persons which is managed or administered in Mauritius

4.3.2 Exclusions from the definition of resident:

S 73 A

A company holding a Category 2 Global Business Licence under the Financial Services Development Act 2001 is not resident in Mauritius and hence not subject to income tax.

4.3.3 Ceasing of residency provided for in the Act

None

5. Time Tax is Levied

S 5 (2)

Income shall be deemed to be derived by a person when:

(a) it has been earned or has accrued; or
(b) it has been dealt with in his interest or on his behalf, whether or not it has become due or receivable.

Companies with accounting year ending on 30 June should submit their returns and pay the tax due for the preceding income year by 31 January. Other companies should submit their returns and pay the tax due for the preceding income year by 30 September.

6. Included in Tax Base

For residents, it is worldwide income

For non-residents, it is income sourced from Mauritius

7. Year of Assessment

1 July to 30 June

8. Computation of Taxable Income

8.1 Exemptions

8.1.1 Partial exemptions (amounts exempt irrespective of the identity of the recipient):

Second Schedule

- 75 per cent of the proceeds from the sale of bagasse by a miller to another miller for the purpose of generating firm electrical power.
- 60 per cent of the proceeds from the sale of firm electrical power or continuous electrical power generated from bagasse by a miller to the Central Electricity Board after deduction of the exemption at (a).
- 50 per cent of the premium paid by the Mauritius Sugar Syndicate to millers producing such types of sugar as may be approved by the Mauritius Sugar Authority.
- 50 per cent of the incremental net income obtained through an increase in output from a sugar growing unit after at least 50 per cent of the land cultivated in cane are incorporated in one or more Land Area Management Units, on such conditions as may be prescribed
- the income derived from a sugar growing unit in respect of the first 60 tons of sugar accruing

8.1.2 Absolute exemptions (taxpayers enjoying completed exemption from tax on income):

Second Schedule of the Act (Parts I, III, IV)

- The registered owner of a foreign vessel from the operation of the vessel
- The registered owner of a local vessel registered in Mauritius provided the income is derived from
deep sea international trade only
- An international organisation approved by the Minister.
- A company holding a Human Resource Development Certificate and starting operations within a
period not exceeding 3 years as from 1 July 2001. The period of exemption is limited to 5 income
years as from the year in which the company starts operations.

- Dividends:
(a) paid by a company resident in Mauritius;
(b) paid by a co-operative society registered under the Co-operative Societies Act;
(c) receivable from outside Mauritius by a company holding a regional development certificate.

- Interest payable on
(i) a tax reserve certificate issued under the Tax Reserves Certificates Act
(ii) A debenture issued under the Loans Act or a loan chargeable on the Consolidated Fund
where the debenture was issued or the loan was made with the condition that the interest
on it would be so exempt
(iii) Such bonds, bearing interest at progressive or variable rate and issued by the Bank of
Mauritius, as may be approved by the Minister
(iv) Call and deposit accounts held with any bank under the Banking Act 1988 by a corporation
holding a Category 1 Global Business Licence under the Financial Services Development Act
2001
(v) Bank deposits held as guarantee by a company engaged in aircraft leasing and approved by
the Minister

- Interest paid to a non-resident by a corporation of a kind approved by the Minister
- Royalty payable to a non-resident by a corporation holding a Category 1 Global Business Licence
under the Financial Services Development Act 2001 or by a bank holding a Class B Banking Licence
under the Banking Act 1988 or a trust, as the case may be.
- Dividends or other distributions paid by a company holding a Category 2 Global Business Licence
under the Financial Services Development Act 2001 to any person
- Interest, rents, royalties, compensations and other amounts paid by a company holding a Category
2 Global Business Licence under the Financial Services Development Act 2001 to a non-resident
- Income derived from activities within the freeport zone by a company licensed under the Freeport
Act. (changes made)
- Gains or profits derived from the sale of units or of securities
- Profits derived from the cultivation of sugar cane on new lands as certified by the Sugar Insurance
Fund Board
- Income derived by a holder of a gaming house licence under the Gaming Act from the operation of
his gaming house
- Value of equity shares in a start-up company received in consideration for legal, accounting,
advertising and other professional services rendered in connection with the setting up of the
company provided that the shares are held for a period of at least 3 years
- Income derived by a company holding a Category 2 Global Business Licence under the Financial
Services Development Act 2001.
- Gains or profits derived from the sale of shares, debt obligations or other securities of a company
holding a Category 2 Global Business Licence under the Financial Services Development Act 2001 by
a non-resident.
- Gains derived by any person from the sale of land previously acquired by him from a planter
implementing the Voluntary Retirement Scheme under the Sugar Industry Efficiency Act 2001.
- Gains derived by the Trust established under the Sugar Industry Efficiency Act 2001 or a body
controlled by the Trust from the sale of land acquired pursuant to sections 10 and 12 of that Act.
- Payments to a planter in respect of bagasse for uses other than the manufacture of sugar.
- Income derived by a planter and by a person with whom the planter has entered into a
management contract duly registered with the Mauritius Sugar Authority for the cultivation of sugar
cane on lands owned by the planter.
- Gains derived by a planter from the sale of land provided that the proceeds are used exclusively for
the implementation of the Voluntary Retirement Scheme under the SIE Act 2001.

8.2 Deductions and recoupments

8.2.1 Allowable deductions

S 57 - S67 G

- Expenditure incurred:

(i) in the production of gross income and
(ii) on interest in the production of income

As per (i) above, companies are allowed to deduct 200 per cent of expenditure incurred on emoluments in respect of a disabled person or emoluments and training costs in respect of an employee employed in any business set up in the Island of Rodrigues.

- Losses as set out at 8.4 below.
- Bad debts and irrecoverable sums of a company which is proved to have become bad and have been actually written off as a bad debt. In the case of banks or of financial institutions as may be approved by the Minister, the following can be deducted:

(i) the amount of any irrecoverable loan due by a company in liquidation in respect of which
winding-up procedures have started; and
(ii) the amount of a specific loan due by a tax incentive company and which is considered to be a
bad and irrecoverable debt, subject to a prescribed limit.

- Pensions to former employees or to their surviving spouses where conditions of section 62 of the
Act are satisfied.
- Annual allowance and Investment Allowances as specified at 8.3 below
- Pre-operational expenses incurred by tax incentive companies incorporated on or after 1 July 1993
- Twice the amount of marketing and promotional expenses incurred on overseas marketing and
export promotion by company engaged in tourism or export activities.
- Investment in the share capital of a start-up company at the rate of 33 1/3 per cent in that income
year and in each of the 2 succeeding income years.
- Expenditure incurred in the setting up of social infrastructure
- Contributions to superannuation fund (a fund or scheme established for the benefit of the
employees of an employer and approved by the Commissioner), road fund, sport clubs and sport
training centres,National Solidarity Fund,employees’ share scheme, national ambulance services and
donations to charitable institutions.

8.2.2 Valuation of inventory/trading stock

The value of trading stock to be taken into account shall be determined in accordance with Mauritius Accounting standard 5 (MAS 5) on the valuation and presentation of stocks and work in progress.

The LIFO formula should not be used to assign costs to stocks and work in progress.

8.2.3 Reserves and provisions

No deduction allowed except in respect of provision for bad debt made by banks on certain specific loans.

8.2.4 Non-deductible expenses

S 68 and S 26No deduction shall be made in respect of -

(a) any investment, expenditure or loss to the extent to which it is capital or of a capital nature;
(b) any expenditure or loss to the extent to which it is incurred in the production of income which is exempt income;
(c) any reserve or provision of any kind;
(d) any expenditure or loss recoverable under a contract of insurance or of indemnity;
(e) any expenditure incurred in providing business entertainment or any gift;
(f) any tax payable under the Land (Duties and Taxes) Act 1984;
(g) income tax or foreign tax;
(h) any expenditure or loss to the extent to which it is of a private or domestic nature.

8.2.5 Recoupments

The Act provides for recoupment when certain deductions previously granted are withdrawn such as bad debts and irrecoverable sums that are subsequently recoved or sale of assets on which annual and investment allowances have been claimed before the prescribed date.

8.3 Depreciable regime

8.3.1 Tangibles (movable and immovable assets, for example plant and machinery)

S 63 & S 24

Annual allowance

Capital expenditure used exclusively to the production of gross income can be deducted by way of annual allowance if they are incurred for:

(a) the acquisition, construction or extension of any industrial premises or of a hotel;
(b) the acquisition of plant or machinery;
(c) agricultural improvement on agricultural land;
(d) scientific research; or
(e) the acquisition or improvement of any other item of a capital nature other than non-industrial premises.

The rate of annual allowances as set out in Income Tax Regulations 1996 are as follows:

Capital expenditure incurred on - Rate of annual allowance Percentage of cost

Industrial premises excluding hotels 5
Hotels 20
Plant or Machinery costing 10,000 rupees or less 100
Plant or Machinery costing more than 10,000 rupees -
(a) Ships or aircrafts 10
(b) Aircrafts and aircraft simulators leased by a 100 company engaged in aircraft leasing
(c) Furniture and fittings 10
(d) Motor Vehicles 20
(e) Electronic and high precision machinery or equipment, 331/3
computer hardware and peripherals and computer software
(f) Other 20
Agricultural improvement on agricultural land 20
Capital expenditure on scientific research 20
Any other item of a capital nature other than non-industrial premises 5

S 64 & S 25

Investment allowance

Companies can also benefit from a 25 % investment allowance if they incur capital expenditure on:
(a) the construction of industrial premises;
(b) the acquisition of new plant and machinery; or
(c) the acquisition of computer softwareS 64 A

Additional Investment Allowance

Manufacturing companies incurring capital expenditure on the acquisition of state-of-the-art technological equipment before 1 July 2004, are allowed an additional deduction of 25 %.

8.3.2 Intangibles/incorporeals (for example, copyright, patents, goodwill and other intellectual rights)

These fall under "Any item of a capital nature other than non-industrial premises" (Refer to 8.3.1 above) and the rate of annual allowance applicable in this respect is 5 per cent

8.4 Treatment of losses

S 59

Losses made in an income year may be deducted when computing net income for that income year. If the amount of a loss cannot be fully relieved, the unrelieved amount can be carried forward and set off against net income derived in succeeding income years, subject to such conditions as may be prescribed.

Where a wholly owned subsidiary incorporated on or after 1 July 1993 which is a tax incentive company satisfies the Commissioner that it has in an income year incurred a loss, it may transfer in that income year any unrelieved loss to its holding company.

Where a miller who is not also a planter satisfies the Commissioner that he has in an income year incurred a loss, he shall be entitled to transfer in that income year any unrelieved loss to a planter related to the miller in proportion to the share of direct or indirect interest of the planter with the miller or of the miller with the planter.

Where a subsidiary company which operates a business in the Island of Rodrigues satisfies the Commissioner that it has in an income year incurred a loss, it may transfer in that income year any unrelieved loss to its holding company in Mauritius.

9. Foreign Exchange Losses and Gains

Exchange profits and losses arising on accounts that record a company's ordinary business transactions are taxable or deductible as the case may be. However, exchange gains/losses in connection with transactions involving capital assets are generally not recognised for income tax purposes

10. Branch Profits Tax

In general, the taxable income of a branch of a foreign company is computed in the same way as that of a resident company. However, a branch cannot claim a deduction for interest and royalties paid to its foreign head office; such payments are considered to be internal transfers within the same legal entity and therefore purely notional. A branch may deduct management expenses charged to it by a foreign head office provided the charge is reasonable having regard to the nature and extent of the management services rendered. Branch profit remittances suffer no withholding tax.

11. Group Taxation/Consolidated Returns

No group taxation

12. Presumptive Tax Measures (for example, a minimum tax in the form of a gross asset tax)

No presumptive tax

13. Rates

First Schedule Part 1

Tax incentive companies pay tax at the rate of 15 %. Other companies are subject to 25 % corporate tax.

Companies holding Category 1 Global Licence are subject to a 15 % corporate tax. These companies will be allowed a credit in respect of foreign tax where written evidence is presented to the Commissioner showing the amount of foreign tax which has been charged. where no written evidence is produced to the Comisssioner showing the amount of foreign tax charged, the amount of foreign tax shall nevertheless be conclusively presumed to be equal to 80 per cent of the Mauritius tax chargeable with respect to that income, thus reducing the effective tax rate to 3 per cent.

14. Rebates

Sections 69, 70, 71 of the income Tax Act provide for tax credits in respect of-

- Investment made in certain categories of companies i.e tax incentive and companies listed on the stock exchange.

- Capital expenditure incurred by modernisation and Expansion Enterprises

- Exports of goods which are manufactured or produced in Mauritius or the provisison of services to a non resident.

However, tax incentive companies are not entitled to any such credits.

Please note also that section 72 of the Income Tax Act limits the aggreagte amount of tax credits to such an amount that would not reduce the tax payable after such tax credits to less than 15 per cent of the chargeable income of the company.

15. Withholding Taxes

There is no withholding tax in Mauritius

16. Beneficiaries of Revenue

National Government

1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

Personal Income Tax, Income Tax Act No. 16 of 1995

2. Department Responsible for Administration

Income Tax Department

3. Definition and Classification

Individuals includes married women and profits generated by a société (partnership) is taxed in the hands of the individual partners

4. Time Tax is Levied

Income shall be deemed to be derived by a person when -

(a) it has been earned or has accrued; or
(b) it has been dealt with in his interest or on his behalf, whether or not it hasbecome due or receivable.

Earned income derived from outside Mauritius shall be deemed to be derived by a person when -

(a) it is received in Mauritius by him or on his behalf; or
(b) it is dealt with in Mauritius in his interest or on his behalf

5. Basis of Taxation

5.1 Source-based or residence based

The Mauritian Income Tax system is based on both the source and residence principle

5.2 If source, define:

5.2.1 Actual source

All income derived from Mauritius irrespective of whether the person was resident in Mauritius or elsewhere

5.2.2 Deemed source

None

5.3 If residence,

5.3.1 Define resident

A person who -

(i) has his domicile in Mauritius unless his permanent place of abode is outside
Mauritius;
(ii) has been present in Mauritius in that income year, for a period of, or an aggregate
period of, 183 days or more; or
(iii) has been present in Mauritius in that income year and the 2 preceding income
years, for an aggregate period of 270 days or more;

5.3.2 Exclusions from the definition of resident:

None

5.3.3 Ceasing of residency provided for in the Act

None

6. Included in Tax Base

World-wide income

7. Year of Assessment

The year of assessment for individuals is the same as for bodies corporate, that is, from 1st July to 30th June (12 months)

8. Computation of Taxable Income

8.1 Exemptions (do not only indicate the heading, but provide a brief explanation)

8.1.1 Partial exemptions (amounts exempt irrespective of the identity of the recipient):

SECOND SCHEDULE

PART II

4. The first one million rupees of any sum received by way of severance allowance.
5. The first one million rupees of any sum received by way of retiring allowance by a person who has attained the appropriate retiring age and retires after completing not less than 10 years' employment.

13, 14, 18

That portion of the emoluments of an expatriate employee or of a Mauritian citizen who has been abroad for 10 income years, that will, in respect of an income year, reduce his tax liability on the emoluments derived by him from the enterprise or company to 50 per cent and working in the following companies

(i) a pioneer status enterprise,
(ii) an export enterprise,
(iii) a company engaged in electronics and high-technology activities,
(iv) a company holding a regional headquarters certificate or
(v) a company engaged wholly in the management of a venture capital fund,

[(i) to (v) limited to 2 employees for each enterprise or company, and period of exemption limited to 4 income years.]

(vi) operating in the freeport zone;
(vii) duly authorised by the Financial Services Commission established under the Financial Services Development Act 2001, to conduct any of the business activities referred to in item 25 of Part IV of the First Schedule;
(viii) holding a Category 1 Global Business Licence under the Financial Services Development Act 2001;(ix) holding a Category 2 Banking Licence under the Banking Act and who is employed by that company to carry out the business activities covered by that licence; or
(x) managing an equity fund,

[(vi) to (x) period of exemption limited to 4 income years.]

(xi) company holding an investment certificate in respect of specified information and communication services under the Investment Promotion (ICT Scheme) Regulations 2002

[for (xi) the number and the full names of the expatriate employees or specified Mauritian employees and the period of the exemption in respect of each of the employees would be specified by the Board of Investment established under the Investment Promotion Act.

PART III

2. (a) The first 75,000 rupees receivable as interest from:-
(i) Government securities;
(ii) bills issued by the Mauritius Civil Service Mutual Aid Association Ltd; or
(iii) fixed deposit or savings accounts in Mauritius

(b) Where interest receivable is in the joint name of the spouses and neither spouse is a dependent spouse, the exemption shall be allowed in any proportion as may be claimed but should not exceed Rs 150,000 in aggregate.

PART IV

3. Income derived from a sugar growing unit -

(a) in the case of a couple, where the income is in their joint names, in respect of the first 120 tonnes of sugar accruing, provided that the exemption is allowed in the same proportion as the income is declared by the couple in their tax returns; or
(b) in any other case, in respect of the first 60 tonnes of sugar accruing,

5. 75 per cent of the proceeds from the sale of bagasse by a miller to another miller for the purpose of generating firm electrical power.

6. 60 per cent of the proceeds from the sale of firm electrical power or continuous electrical power generated from bagasse by a miller to the Central Electricity Board after deduction of the exemption under item 5.

7. 50 per cent of the premium paid by the Mauritius Sugar Syndicate to millers producing such types of sugar as may be approved by the Mauritius Sugar Authority.

8. 50 per cent of the incremental net income obtained through an increase in output from a sugar growing unit after at least 50 per cent of the land cultivated in cane are incorporated in one or more Land Area Management Units, on such conditions as may be prescribed.

8.1.2 Absolute exemptions (taxpayers enjoying completed exemption from tax on income)

Second Schedule
Part I

Income derived by:

23. A non-citizen who is approved by the Minister or is a member of a class approved by the Minister, from personal or professional services performed by him within Mauritius, where in the opinion of the Minister -

(a) the services rendered or to be rendered by the non-citizen are primarily and principally
directed at assisting the Government in the development of Mauritius; and
(b) the income derived by the non-citizen is liable to income tax in another country.

24. A non-citizen who is approved by the Minister or is a member of a class approved by the Minister -
(a) from personal or professional services performed by him in Mauritius for or on behalf of
an employer who is also a non-citizen; or
(b) from any maintenance allowance, scholarship or bursary provided for or paid to him,

where the income is derived by him during and in respect of his presence in Mauritius for
the purpose of providing professional or expert advice or assistance, teaching or
lecturing, making investigations, or receiving education, training or experience, under an
arrangement for assistance entered into by the Government of Mauritius with the
government of any other country or with an international organisation for the purpose of
providing, on any basis, professional, expert, educational, economic, technical or cultural
assistance or administrative or other training, or the means or facilities for investigations.

25. A non-resident expatriate engineering and support service personnel required by a pioneer status enterprise or by any company engaged in electronics and high-technology activities for the installation and maintenance of equipment and training of local staff.

26. A non-resident from the provision in Mauritius of consultancy services or training otherwise than under a contract of employment provided that the period of the services or training does not in the aggregate exceed 183 days in an income year.

32. A non-citizen from outside Mauritius and who is resident in Mauritius

PART II

1. Emoluments derived from the office of the President or Vice-President.

2. Any lump sum or gratuity paid under a pension law.

3. Income derived by way of basic retirement pension payable under the National Pensions Act.

6. Any lump sum received by way of death gratuity or as consolidated compensation for death or injury or as commutation of pension and paid -

(a) by virtue of any enactment;
(b) from a superannuation fund; or
(c) under a personal pension scheme approved by the Commissioner.

7. That portion of any sum payable by the Government of Mauritius by way of a gratuity in relation to a public officer employed on a contract which is equivalent to 7 1/2 per cent of the basic salary payable under the contract in respect of the contract period.

8. Any rent allowance payable to a person appointed to an office in -

(a) the Police Force;
(b) the Fire Services;
(c) the Forests Division of the Ministry of Agriculture and Natural Resources;
(d) the Prisons and Industrial School Service;
(e) the Ministry of Fisheries;
(f) the Department of Civil Aviation; and
(g) the Fire Unit of the Mauritius Marine Authority.

9. Any housing allowance not exceeding 100 rupees per month payable by an employer to an employee under any enactment or by virtue of an award made under an enactment.

10. Any transport allowance payable by an employer to an employee by virtue of the terms and conditions of service equivalent to -

(a) the return bus fare between residence and place of work;
(b) commuted travelling allowance and travel grant payable by the Government of Mauritius and
the local authority to their employees;
(c) the actual allowance paid or 25 per cent of the monthly basic salary up to a maximum of
5,730 rupees, whichever is the lesser, provided that the employee makes use of a private car
registered in his own name for attending duty and for the performance of the duties of his
office or employment.

11. Any reimbursement of medical expenses to home-based staff of overseas missions.

12. The emoluments derived by a seaman who is employed on a vessel registered in Mauritius or on a foreign vessel.

15. Emoluments of a non-citizen who holds office in Mauritius as an official of a Government other than the Government of Mauritius and is posted to Mauritius for that purpose.

16. Director's fees payable to a non-resident director of a company

17. Any advantage in money or in money’s worth received as lump sum by an employee voluntarily terminating his contract of employment in the context of a factory closure pursuant to the Cane Planters and Millers Arbitration and Control Board Act or under the Voluntary Retirement Scheme under the Sugar Industry Efficiency Act 2001.

PART III

1. Dividends -

(a) paid by a company resident in Mauritius;
(b) paid by a co-operative society registered under the Co-operative Societies Act; or
(c) receivable from outside Mauritius by a company holding a regional development certificate.

3. Interest payable on -

(a) a tax reserve certificate issued under the Tax Reserve Certificates Act;
(b) a debenture issued under the Loans Act or a loan chargeable on the Consolidated Fund
where the debenture was issued or the loan was made with the condition that the interest
on it would be so exempt;
(c) a balance maintained in a domestic bank by an individual who is not resident in Mauritius;
(d) a deposit made and maintained for a continuous period of not less than 3 years by an
individual in a domestic bank or in non-bank financial institution authorised to carry on
deposit-taking business in Mauritius by the Central Bank under section 13A(2) of the
Banking Act 1988;
(e) such bonds, bearing interest at progressive or variable rate and issued by the Bank of
Mauritius, as may be approved by the Minister;
(f) call and deposit accounts held with any bank under the Banking Act 1988 by a corporation
holding a Category 1 Global Business Licence under the Financial Services Development Act
2001;
(g) bank deposits held as guarantee by a company engaged in aircraft leasing and approved by
the Minister.

4. Any interest and bonus derived from the Housing Savings Scheme of the Mauritius Housing
Corporation Ltd.

5. Interest paid to a non-resident by a corporation of a kind approved by the Minister.

6. Royalty payable to a non-resident by a corporation holding a Category 1 Global Business Licence under the Financial Services Development Act 2001 or by a bank holding a Class B Banking Licence under the Banking Act 1988 or a trust, as the case may be.

7. Dividends or other distributions paid by a company holding a Category 2 Global Business Licence u under the Financial Services Development Act 2001 to any person.

8. Interest paid by a company holding a Category 2 Global Business Licence under the Financial Services Development Act 2001 to a non-resident.

PART IV

1. Gains or profits derived from the sale of units or of securities.

4. Payments to a planter in respect of bagasse for uses other than the manufacture of sugar.

9. Profits derived from the cultivation of sugar cane on new lands certified by the Sugar Insurance Fund Board to have been brought under cultivation during the calendar years 1996 and 1997 for a period of 6 consecutive years as from the year following the year in which the new lands were brought under cultivation.

10. Income derived by a planter and by a person with whom the planter has entered into a management contract duly registered with the Mauritius Sugar Authority for the cultivation of sugar cane on lands owned by the planter.

11. Income derived from the operation of a gaming house.

12. Income derived by any person in the form of maintenance allowance or other benefit provided in respect of his attendance at a university, college, school or other educational institution in terms of a scholarship, bursary, exhibition or other education award.

13. Income which is expressly exempt from income tax by any other enactment to the extent of the exemption so provided.

14. Value of equity shares in a start-up company received in consideration for legal, accounting, advertising and other professional services rendered in connection with the setting up of the company provided that the shares are held for a period of at least 3 years.

15. Income derived by a company holding a Category 2 Global Business Licence under the Financial Services Development Act 2001.

16. Rents, royalties, compensations and other amounts paid by a company holding a Category 2 Global Business Licence under the Financial Services Development Act 12001 to a non-resident.

17. Gains or profits derived from the sale of shares, debt obligations or other securities of a company holding a Category 2 Global Business Licence under the Financial Services Development Act 2001 by a non-resident.

18. Gains derived by a planter from the sale of land provided that the proceeds are used exclusively for the implementation of the Voluntary Retirement Scheme under the Sugar Industry Efficiency Act 2001.

19. Gains derived by any person from the sale of land previously acquired by him from a planter implementing the Voluntary Retirement Scheme under the Sugar Industry Efficiency Act 2001.

20. Gains derived by the Trust established under the Sugar Industry Efficiency Act 2001 or a body controlled by the Trust from the sale of land acquired pursuant to sections 10 and 12 of that Act.

8.2 Deductions and recoupments

8.2.1 Allowable deductions

Deduction in connection with calculation of income

Deduction in connection with employment

Any expenditure which is wholly, exclusively and necessarily incurred by a person in performing the duties of an office or employment shall be deductible from his emolument income. This include expenditure for attending training courses in connection with the duties of an office or employment by a member of a recognised professional body (limited to Rs 20,000)

Deduction in connection with other income

Any expenditure or loss shall be deductible from the gross income

This includes

(i) expenditure ncurred by a person on the repair of premises, machinery or plant, or on rent, or on
export duties, rates and taxes, other than income tax or any other tax on income or profits.
(ii) an amount equal to 200 per cent of expenditure incurred by a person in an income year shall be
deductible from his gross income in that income year where the expenditure is incurred on -

(a) emoluments in respect of a disabled person; or
(b) emoluments and training costs in respect of an employee employed in any business set up
in the Island of Rodrigues.

(iii) Expenditure incurred on interest in the production of income

(iv) Bad debts and irrecoverable sums

The amount of a debt or sum which is proved to have become bad and to have been actually written off as a bad debt by the person in an income year may be deducted from gross income.

(v) Contributions to superannuation fund

An employer may deduct any amount irrevocably paid by him to provide -

(a) a pension or retirement allowance to his employees and their dependants under a
superannuation fund; and
(b) for the medical expenses of his employees and their dependants under a scheme approved
by the Commissioner.

Where an amount paid by an employer under subsection (1) is a lump sum payment in respect of past services of employees, one-tenth of the payment shall be deductible in the income year in which the payment is made and in each of the 9 succeeding years.

(vi) Pensions to former employees

Pension to any former employee in the business of that person subject to the approval of the commissioner of income tax.

Personal Reliefs and Deductions (Emoluments)

(1) Emoluments relief 15% of total emoluments (limit Rs125,000)
(2) Retirement pension relief Amount of pension (limit Rs 75,000)
(3) Basic personal deduction Rs 75,000
(4) Deduction for dependent spouse Rs 60,000

(5) Deduction for dependent children (limited to 3 children)-

(a) child under the age of 18 at any time in the income year (Rs 25,000)
(b) child over the age of 18 at any time in the income year and receiving full-time instruction at an
educational institution or serving under articles or indentures with a view to qualifying in a trade
or profession or being unemployed (Rs 25,000)
(c) child receiving full-time instruction at any time in the income year at a university in Mauritius, or
attending a course at a polytechnic in Mauritius or at an educational institution providing tertiary
education and approved as such by the Commissioner, or serving under articles or indentures
outside Mauritius with a view to qualifying in a trade or profession (Rs 50,000)
(d) child receiving full-time instruction at any time in the income year at a university outside Mauritius
or attending a course at a polytechnic outside Mauritius (Rs 100,000)
(e) child attending a course at any time in the income year at the Industrial Vocational Training
Board as a non-sponsored student, or at a State-owned, or approved, technical school
Rs 30,000)

(6) Expenses incurred on tuition fees and school fees (limited to Rs 8,000 per child)

(7) Deduction for handicapped persons Rs 50,000(child, spouse, handicapped person for whom one is
your tutor)

(8) Alimony and maintenance in accordance with court order (No limit)

(9) Relief for contributions to approved superannuation/pension funds or schemes to a widow’s and children’s fund

(10) Interest relief Interest payable on secured housing loans or loans taken to finance tertiary education of dependent children (limit: Rs 125,000 for self and Rs 250,000 for couple)

Investment relief

40% of :-

(a) amount invested in the share capital of a tax incentive company or a company listed on the stock
exchange
(b) investments made in newly issued securities of an investment trust company
(c) contributions made to an approved medical savings scheme or an investment club formed in
accordance with the Stock Exchange Act 1988

The relief in any one income year shall not exceed Rs50,000

Any excess can be deducted over the two succeeding income years subject to the limit.

(11) Deduction for medical expenses

75% of expenses incurred in a health institution or hospital (net of refund)Maximum amount allowable in one year is Rs 20,000 for treatment in Mauritius and Rs 30,000 for treatment abroad. Any excess can be deducted over the two succeeding income years subject to the limit.

(12) Donations to charitable institution limited to Rs 20,000

(13) Deduction for contribution to the National Solidarity Fund established under the Finance and Audit Act

(14) Education and training for self (limited to Rs 25,000)

Only in respect of fees payable le to a recognized institution

(15) Relief for life insurance premium (limited to Rs 80,000)

(17) Savings relief

(a) Relief for premium on personal pension scheme
(b) Relief for premium on retirement annuity
(c) Relief for contribution to medical scheme(including ambulance service)

relief limited to 20% of net income

Personal Reliefs and Deductions (Other Income)

(1) Agricultural income relief 15% of net income derived from agriculture (limited to Rs 100,000)

8.2.2 Valuation of inventory/trading stock

Same as for bodies corporate

8.2.3 Reserves and provisions

Not allowable as deductions

8.2.4 Non-deductible expenses

(a) any investment, expenditure or loss to the extent to which it is capital or of a capital nature;

(b) any expenditure or loss to the extent to which it is incurred in the production of income which is exempt income;

(c) any reserve or provision of any kind;

(d) any expenditure or loss recoverable under a contract of insurance or of indemnity;

(e) any expenditure incurred in providing business entertainment or any gift;

(f) any tax payable under the Land (Duties and Taxes) Act 1984;

(g) income tax or foreign tax;

(h) any expenditure or loss to the extent to which it is of a private or domestic nature.

8.2.5 Recoupments

Same as for corporate taxpayers

8.3 Depreciable regime

8.3.1 Tangibles (movable and immovable assets, for example plant and machinery)

Same as for bodies corporate except for additional capital allowance which is not provided to individuals

8.3.2 Intangibles/incorporeals (for example, copyright, patents, goodwill and other intellectual rights)

Same as for corporate taxpayers

8.4 Treatment of losses

Losses shall not be deducted from or set off against emolument income but may be carried forward and set off against gross income, other than emolument income in the following income year and in the succeeding years.

9. Foreign Exchange Losses and Gains

Same as for corporate taxpayers

10. Rates

Chargeable income Rate of tax
On the first 25,000 rupees 15 per cent
On the remainder 25 per cent

11. Rebates/Tax Threshold

12. Fringe Benefit Taxes (Benefits Flowing from an Employer-Employee or an Office Relationship)

Gross income includes any advantage in money or in money's worth which is salary, wages, leave pay, fee, overtime pay, perquisite, allowance, bonus, gratuity, commission or other reward or remuneration in respect of or in relation to the office or employment of that individual, other than passages, by sea, air or land between Mauritius and another country, provided under the contract of employment.

Where the Commissioner is satisfied that the whole or part of any advantage has necessarily to be provided by an employer for a person for the performance of the duties of his office or employment, the advantage, or part thereof, shall not be included in the gross income of that person.

A deduction from chargeable income is allowed in respect of car benefit as follows:The actual allowance paid or 25 per cent of the monthly basic salary up to a maximum of 5,730 rupees, whichever is the lesser, provided that the employee makes use of a private car registered in his own name for attending duty and for the performance of the duties of his office or employment.

13. Allowances

14. Treatment of Pension, Provident or Retirement Annuity Fund Income

Pension, retiring allowance and annuity are taxed as ordinary income.

Lump sums received under old age pension and the first Rs 1million of retiring allowance are exempt from income tax.

Contributions by employer to provide a pension or retiring allowance is generally not included in the gross income of the employee.

Relief for premium on retirement annuity is available

15. Treatment of Professional Income

Aggregated to other income of the taxpayer for tax computation

16. Treatment of Investment Income

17. Withholding Taxes

None

18. Beneficiary of Revenue

National Government

1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

2. Department Responsible for Administration

3. Included in Tax Base

4. If Sourced-Based, Define (If Not Already Done)

4.1 Actual source

4.2 Deemed source:

5. Rates

6. Beneficiary of Revenue

1. Dividends

- Dividends means a distribution authorised by the Board of Directors of a company and made out of the retained earnings of the company, after having made good any accumulated losses at the beginning of its accounting period, either in cash or in shares to its shareholders. It includes distribution to a unitholder out of the net income derived by a unit trust scheme.

- Dividends payable are not deductible in computing the chargeable income of a company.

- Dividends receivable from a resident company are exempt from tax. However, where a company’s income includes dividends which are exempt, the expenses incurred to produce such income should be added back.

2. Interest

Interest paid by individuals in the production of business income may be deducted from such income

Interest income is included in the gross income of an individual and is taxable under the CPS.For companies interest received is treated as income and interest paid as expenditure.

Interest Relief for individuals

Interest payment during an income year is deductible from net income. This deduction is restricted to interest on secured housing loans and interest on loans taken by parents to finance Tertiary Education of their children. The deduction is limited to Rs 250,000 per couple.

2. (a) The first 75,000 rupees receivable in any income year by an individual personally or as an associate in a société or as a beneficiary in the estate of a deceased person in respect of interest on - (i) government securities;
(ii) bills issued by the Mauritius Civil Service Mutual Aid Association Ltd; or
(iii) fixed deposit or savings accounts in Mauritius with a bank or other institution authorised
by any other enactment to accept money on fixed deposit or savings accounts and to pay
interest on it in Mauritius.

3. Interest payable on -

(a) a tax reserve certificate issued under the Tax Reserve Certificates Act;
(b) a debenture issued under the Loans Act or a loan chargeable on the Consolidated Fund where
the debenture was issued or the loan was made with the condition that the interest on it would
be so exempt;
(c) a balance maintained in a domestic bank by an individual who is not resident in Mauritius;
(d) a deposit made and maintained for a continuous period of not less than 3 years by an individual
in a domestic bank or in non-bank financial institution authorised to carry on deposit-taking
business in Mauritius by the Central Bank under section 13A(2) of the Banking Act 1988;
(e) such bonds, bearing interest at progressive or variable rate and issued by the Bank of Mauritius,
as may be approved by the Minister;
(f) call and deposit accounts held with any bank under the Banking Act 1988 by a corporation
holding a Category 1 Global Business Licence under the Financial Services Development Act 2001;
(g) bank deposits held as guarantee by a company engaged in aircraft leasing and approved by
the Minister.

4. Any interest and bonus derived from the Housing Savings Scheme of the Mauritius Housing Corporation Ltd.

5. Interest paid to a non-resident by a corporation of a kind approved by the Minister.

8. Interest paid by a company holding a Category 2 Global Business Licence under the Financial Services Development Act 2001 to a non-resident.

3. Royalties

Royalties are included in the definition of gross income and therefore subject to tax. However, royalty payable to a non-resident by a corporation holding a Category 1 Global Business Licence under the Financial Services Development Act 2001 or by a bank holding a Class B Banking Licence under the Banking Act 1988 or a trust, are exempt from tax.

4. Fees

Treated as ordinary income

5. Rents

Rental income exceeding Rs 6,000 derived by individuals is taxable under the CPS system

1. Mining Tax

2. Insurance Business

As per the Regulations, when a company carries on life insurance business in conjunction with insurance business of any other class, the life insurance business shall, for the purposes of the Act, be treated as a separate business from any other class of business carried on by the company.
The net income of an insurance company conducting any insurance business, other than that relating to life insurance, in any income year, shall be calculated by -

(a) taking the gross premiums and interest and other income derived by the company from that business in that income year less any such premium returned to an insured and/or paid on re-insurance;
(b) deducting from the amount obtained under sub-paragraph (a) a reserve for unexpired risks outstanding at the end of that income year in respect of that business;
(c) adding to the amount obtained under sub-paragraph (b) a reserve for unexpired risks outstanding at the commencement of that income year; and
(d) deducting from the amount calculated under sub-paragraph (c) -

(i) the actual losses of the company less any amount recovered under re-insurance in respect of
loss; and
(ii) all allowable deductions.

(3) The reserve specified in paragraphs (2) (b) and (c) shall be calculated at the percentage adopted by the insurance company in relation to its operation as a whole, and that percentage shall be the same whether the unexpired risks for which the reserve is created are outstanding at the commencement or at the end of an income year.

(4) Where the insurance company is a non-resident company it shall be entitled to claim -

(a) any agency fees incurred in Mauritius; and
(b) a fair proportion of the expenses of the head office of the company.

(5) The net income of an insurance company which carries on life insurance business in any income year shall be the difference between -

(a) the income from investment held by the company in connection with its life insurance business
but excluding that attributable to the general annuity business and pension business in that
income year; and
(b) the sum of -

(i) all management expenses incurred and all commissions paid by the company; and
(ii) all allowable deductions.

(6) Where an insurance company which carries on life insurance business receives premiums outside Mauritius, the net income of the company shall be the difference between -

(a) that part of the total investment income of the company which bears the same proportion to the total investment income as the premiums received in Mauritius bear to the total premiums received by the company; and
(b) in the case of a resident company, the sum of

(i) all management expenses incurred and all commissions paid by the company; and
(ii) all allowable deductions;

(c) in the case of a non-resident company, the sum of -

(i) all management expenses and commissions paid in Mauritius;
(ii) all allowable deductions;
(iii) any agency expenses incurred in Mauritius;
(iv) a fair proportion of the expenses of the head office of the company.

(7) Where a life insurance company carries on general annuity business and pension business in conjunction with ordinary life insurance business, the net income of the company derived from the general annuity business and pension business shall, with respect to each class, be computed separately and shall be calculated -

(a) by taking the liability of the company under its general annuity contracts or pension contracts, as the case may be, at the beginning of the income year, as assessed by an actuarial valuation;
(b) by adding to the amount obtained under paragraph (a) the following items in respect of the general annuity business or pension business, as the case may be, for the income year-

(i) the premiums and considerations received;
(ii) the investment income; and

(c) by deducting from the amount arrived at under paragraph (b) such amounts as represent for the income year -

(i) annuities or pensions paid, as the case may be;
(ii) surrendered policies;
(iii) the liability of the company at the end of the income year as assessed by an actuarial
valuation.

(8) In this regulation-

"insurance" in relation to a business, means insurance or guarantee against loss, damage or risk of any kind;

"general annuity business" means annuity business other than pension business;

"pension business" means all business transacted in connection with pension, life insurance and for the benefit of a surviving spouse and children, as approved by the Commissioner.

18. Ascertainment of the net income of a shipping or aircraft company

(1) For the purposes of section 50 (1) of the Act, the net income of a company carrying on shipping or aircraft business shall be -

(a) where the company is resident in Mauritius, the difference between the gross income derived by the company from Mauritius or elsewhere and the allowable deductions;

(b) where the company is not resident in Mauritius, determined in accordance with the following formula -

a
—— x p
g

where -

a = amount payable in respect of carriage of passenger, cargo or mail embarked or shipped in Mauritius and any other gross income derived from Mauritius;

g = total gross income as certified by the authority of the country in which the effective management of the business is situated;

p = total gains or profits of the company.

3. Farming

4. Ships and Aircraft Owners

The net income of a company carrying on shipping or aircraft business shall be -

(a) where the company is resident in Mauritius, the difference between the gross income derived by the company from Mauritius or elsewhere and the allowable deductions;

(b) where the company is not resident in Mauritius, determined in accordance with the following formula -

a/g x p, where -

a = amount payable in respect of carriage of passenger, cargo or mail embarked or shipped in Mauritius and any other gross income derived from Mauritius;
g = total gross income as certified by the authority of the country in which the effective management of the business is situated;

p = total gains or profits of the company.

5. Other

1. Payment Periods

Our system is based on self assessment

Employees deriving emoluments are subject to PAYE.
Self-Employed persons are taxed under the CPS.

Income Tax Returns are issued annually to registered taxpayers after the end of each income year.

Tax returns must be submitted to the income tax department by 30 September following the income year with any tax due thereon.

Under the CPS an additional statement of income is submitted for the six months ending 31 December. This must be submitted not later than the following 31 March together with any tax due.

2. Rulings

2.1 Possibility of advance rulings

Any person who derives or may derive any income may apply to the Commissioner for a ruling as to the application of this Act to that income upon the payment of a fee. The ruling will be given within 30 days of the receipt of the application and will be binding upon the Commissioner although he may, by publication in the Gazette, notify that a ruling which has been published shall cease to be binding with effect from a date which shall not be earlier than the date of the notice.

2.2 Publication of rulings

A ruling must be published by the Commissioner in such manner as he thinks fit except that the identity of the person to whom it relates is not be indicated.

3. Codification of Revenue Practices

The Income Tax department publish several brochures to explain the functioning of the tax system, especially for companies on the issue of PAYE

4. Refunds

When tax has been overpaid under PAYE the excess is refunded when the taxpayer submit his return of income at the end of the financial year. Where the refund is made after three months after submission of the return the taxpayer will be entitled to interest at the prevailing bank rate on the amount due.

Any person may make a claim to the Commissioner for a refund of tax paid in excess within 4 years of assessment after the end of the year of assessment in respect of which the tax was overpaid

The Minister may remit or order the refund of the whole or part of any income tax other than the tax payable under compounding of offences.

5. Interest, Charges and Penalties

Refund for overpaid tax- Where the refund is made after 3 months from the date the return of income is submitted, the refund shall carry interest free of income tax at the prevailing Bank rate.

Where an employer fails to pay the amount of tax required to be withheld under PAYE, he shall be liable to pay to the Commissioner, in addition to the tax, a penalty representing 2 per cent of the amount of the tax, excluding the penalty, for each month or part of the month during which the tax remains unpaid.

Where a person fails to submit a Statement of Income (CPS) or return of income, he shall be liable to pay to the Commissioner a penalty representing 5,000 rupees per month or part of the month, until such time as the Statement of Income is submitted. (Maximum of Rs 50,000)

Where a taxpayer fails to pay any income tax due on or before the last day on which it is payable under CPS, he shall be liable to pay to the Commissioner, in addition to the tax, a penalty representing 25 per cent of the amount of tax remaining unpaid.

Where the amount of tax payable on the income (if the half year method of calculation is used) exceeds the amount of any tax paid in accordance with the Statement of Income by more than 60 per cent of the amount of tax payable, the person shall, at the time the return is submitted, pay, in addition to the difference, a penalty representing 25 per cent of the amount in excess of the 60 per cent.

A person who has been required to submit a return shall, not later than the date specified in the notice, submit to the Commissioner the return of income and at the same time pay any tax payable in accordance with that return together with the appropriate penalty.

Where a taxpayer fails to pay any income tax due on or before the last day on which it is payable he shall be liable to pay to the Commissioner, in addition to the tax, a penalty representing 2 per cent of the amount of tax for each month or part of the month during which the tax remains unpaid.

The penalty under this section shall not, in the aggregate, exceed the amount of income tax remaining unpaid.

The Commissioner may waive the whole or part of any penalty imposed under this Act where he is satisfied that failure to comply with this Act was attributable to a just or reasonable cause.

1. Transfer Pricing Legislation

2. Thin Capitalisation Legislation

3. Controlled Foreign Entities (CFES)

4. Provide a Brief Discussion of General Anti-Avoidance Provisions (Both under common and statutory law)

Under the Income Tax Act, where the Commissioner concludes that any transaction has not een carried out at arm's length and that the person, or one of the persons, who entered into or carried out the transaction, did so for the sole or dominant purpose of enabling the relevant person, either alone or in conjunction with other persons, to obtain a tax benefit, the Commissioner shall assess the liability to tax of the relevant person-

a. as if the transaction or any part thereof had not been entered into or carried out; or
b. in such other manner as the Commissioner considers appropriate to counteract the tax benefit
which would otherwise be obtained.

5. Transactions Between Connected Persons

1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

Capital Gains tax is not applicable in Mauritius

2. Department Responsible for Administration

3. Basis of Taxation (Source-based or residence-based)

4. Time When Tax is Levied

5. Included in Tax Base

6. Exemptions/Exclusions

7. Allowable Deducations

8. Non-Deductible Expenses

9. Roll-Overs

10. Treatment of Losses

11. Rates

12. Rebates

13. Tax Period

14. Withholding Taxes

15. Beneficiary of Revenue

1. Name of Tax and Levied in Terms of Which Levied (Name, Number and Year)

2. Department Responsible for Administration

3. Basis of Taxation (Source-based or residence-based)

4. Time When Tax is Levied

5. Included in Tax Base

6. Exemptions

7. Allowable Deducations

8. Non-Deductible Expenses

9. Treatment of Losses

10. Rates

11. Rebates/Annual Deduction

12. Tax Period

13. Withholding Taxes

14. Beneficiary of Revenue

1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

None

2. Department Responsible for Administration

3. Taxpayer

4. Included in Tax Base

5. Tax Rate

6. Beneficiary of Revenue

1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

None

2. Department Responsible for Administration

3. Taxpayer

4. Included in Tax Base

5. Tax Rate

6. Beneficiary of Revenue

1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

Donation Duty; Registration Duty Act, RL 4/445 of 1804

2. Department Responsible for Administration

Registrar General Department

3. Taxpayer

Beneficiary

4. Included in Tax Base

Value of donation

5. Tax Rate

SALE %
Not exceeding Rs 15,000 10
Exceeding Rs 15,000 but not exceeding Rs 20,000... 12 1/2
Exceeding Rs 20,000 but not exceeding Rs 50,000 15
Exceeding Rs 50,000 but not exceeding Rs 150,000 ... 18
Exceeding Rs 150,000 but not exceeding Rs 250,000 ... 21
Exceeding Rs 250,000 but not exceeding Rs 500,000 ... 24
Exceeding Rs 500,000 but not exceeding Rs 700,000 ... 27
Exceeding Rs 700,000 but not exceeding Rs 1,000,000 ... 30
Exceeding Rs 1,000,000 but not exceeding Rs 2,000,000 ... 35
Exceeding Rs 2,000,000 but not exceeding Rs 5,000,000 ... 40
Exceeding Rs 5,000,000 45

6. Beneficiary of Revenue

Central Government

1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

Campement site tax; Land (Duties and taxes) Act (Part V) and (Part VI) , No 46 of 1984

2. Department Responsible for Administration

Registrar General

3. Taxpayer

Owner of campement site

“Campement site” means any land situated wholly or partly within 81.21 metres of the high water mark and has an access to the sea

4. Included in Tax Base

Part V - Area and zoning of the site

Part VI - Value of campement site and building
"Campement" means any campement site together with any building or structure or part thereof, flat or apartment, thereon used at any time for the purpose of residence.

5. Tax Rate

PART V

RATE OF TAX ZONE
6 rupees per metre square A
5 rupees per metre square B
4 rupees per metre square C
3 rupees per metre square D
2 rupees per metre square E

PART VI

Rate of Tax : 0.5% of the value of campement less amount of campement site tax and general rate leviable to the Local Government Act

6. Beneficiary of Revenue

Central Government

O. Relief From Double Taxation

Belgium
Botswana
Cyprus
Democratic Socialist Republic of Sri Lanka
France
Germany
India
Indonesia
Italy
Kuwait
Luxembourg
Madagascar
Malaysia
Mozambique
Namibia
Nepal
Oman
Pakistan
People’s Republic of China
Singapore
South Africa
Swaziland
Sweden
Thailand
United Kingdom
Zimbabwe