Mauritius has taken a further significant step in the implementation of the OECD’s Pillar Two global minimum tax framework with the publication of the Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026 (“QDMTT Regulations”).
The QDMTT Regulations were made on 28 July 2026, gazetted on 8 August 2026 under Government Notice No. 135 of 2026, and are deemed to have come into operation on 1 July 2025. They provide the detailed rules required for the practical application of the Qualified Domestic Minimum Top-up Tax (“QDMTT”) framework introduced through the Finance Act 2025.
The QDMTT is broadly intended to ensure that in-scope multinational enterprise (“MNE”) groups are subject to a minimum effective tax rate of 15% on relevant profits arising in Mauritius. The introduction of the detailed regulations provides greater clarity on the computation of the QDMTT and the circumstances in which relief or simplification may be available.
De minimis exclusion and safe harbour
One of the important features introduced by the QDMTT Regulations is the de minimis exclusion. Subject to the prescribed conditions and an annual election, the QDMTT for covered persons in Mauritius may be deemed to be nil where the average GloBE revenue is below EUR 10 million and the average GloBE income or loss is either a loss or below EUR 1 million.
The regulations also introduce a transitional Country-by-Country Reporting (“CbCR”) safe harbour. During the transition period, the QDMTT may be deemed to be zero where specified conditions are satisfied, including where the MNE group meets the prescribed revenue and profit thresholds, satisfies the simplified effective tax rate test, or meets the substance-based income exclusion test.
These provisions may significantly simplify the compliance and computational requirements for eligible MNE groups and should therefore form an important part of any QDMTT assessment.
Alignment with OECD Pillar Two guidance
Another important aspect of the QDMTT Regulations is their express reference to OECD Pillar Two guidance. The regulations incorporate a defined body of OECD materials, including the GloBE Rules, Commentary, Administrative Guidance, safe harbour guidance and relevant examples.
This approach is important because the GloBE Rules are highly technical and involve a number of concepts that may require interpretation when applied to specific fact patterns. Reference to OECD guidance provides additional context for taxpayers in understanding how the QDMTT provisions are intended to operate and supports greater consistency with the broader international Pillar Two framework.
What should businesses consider?
For businesses with a Mauritius presence that form part of an MNE group within the scope of Pillar Two, the introduction of these provisions makes it important to assess not only whether a QDMTT liability may arise, but also whether the group can benefit from an applicable de minimis exclusion or safe harbour.
MNE groups should therefore consider reviewing their Mauritius entities, ownership structures, financial information and existing GloBE calculations to determine the potential impact of the QDMTT rules and the compliance requirements that may apply.
How can WTS assist?
WTS Mauritius can assist MNE groups throughout the QDMTT compliance process, from assessing whether the Mauritius entities fall within the scope of the regime, reviewing GloBE computations and determining potential QDMTT exposure, to assessing the availability of the de minimis exclusion and applicable safe harbours.
We can also assist with the preparation and review of QDMTT calculations, supporting information and MRA filing requirements, as well as addressing technical questions arising from the application of the Mauritius legislation and OECD Pillar Two guidance.
With the QDMTT framework now supported by detailed regulations, businesses should consider reviewing their Mauritius position and compliance processes to ensure that the available exclusions, simplifications and reliefs are appropriately considered.
