Cabinet agrees to issue regulations supporting the implementation of the Qualified Domestic Minimum Top-up Tax, including rules on effective tax rate calculations, top-up tax procedures and excluded persons.

The Mauritius Cabinet approved new regulations to support the implementation of its Qualified Domestic Minimum Top-up Tax (QDMTT), providing further guidance on the operation of the domestic minimum tax regime introduced in 2025.

The Cabinet agreed to the promulgation of the Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026, which supplement the existing legislative framework governing the QDMTT. The regulations are intended to support the application of the domestic minimum top-up tax in line with the Global Anti-Base Erosion rules while helping preserve Mauritius’s national tax base.

Implementation guidance

The regulations set out the methodology for computing the effective tax rate used in determining whether a top-up tax is payable under the QDMTT.

They also establish procedures for applying the top-up tax and clarify how the domestic minimum top-up tax should be administered.

Excluded persons

In addition, the regulations identify persons that are excluded from the application of the domestic minimum top-up tax, providing greater certainty over the scope of the regime.

The 2026 regulations are intended to complement the QDMTT framework introduced in 2025 and provide the operational rules required for its implementation.