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CMS Expert Guide to Mastering OECD's Pillar Two in Mauritius

Key stages in the introduction of global minimum taxation

Table of contents
  1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force?
  5.  When will the Undertaxed Payments Rule (UTPR) come into force? 
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
  7. Further comments
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

The Finance (Miscellaneous Provisions) Act 2022 introduced a ‘qualified domestic minimum top-up tax’. However, the section is not yet in force.

3. Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?

No.

4. When will the Income Inclusion Rule (IIR) come into force?

Undetermined.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

Undetermined.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

Yes, provisions have not yet come into operation.

7. Further comments

2 August 2022: the Finance (Miscellaneous Provisions) Act 2022 has been enacted, implementing several measures from the 2022-2023 Budget including the introduction of a 15% domestic minimum top-up tax for resident companies belonging to a multinational entity group with annual revenue of at least EUR 750 million, in line with the proposed Pillar Two rules.