Minimum tax: investment funds excluded, filing date clarified, late-payment penalty halved

The Finance Act 2026 (Act No. 14 of 2026), assented to on 12 August 2026, amends the provisions of the Income Tax Act that impose Mauritius's Qualified Domestic Minimum Top-up Tax (QDMT tax), the domestic counterpart of the OECD Pillar Two global minimum tax. The changes, in section 7(e) to (h) of the Act, touch the definition of excluded persons, the reference point for the return deadline, the penalty rate and the time limit for amended returns. They concern resident companies in multinational groups with consolidated revenue of EUR 750 million or more.

What the rules say

Section 7 of the Finance Act 2026 makes these changes to the QDMT tax provisions in sections 50P to 50Y of the Income Tax Act.

The Act also amends the definition of "financial accounting net income or loss" so that it refers to adjustments made to eliminate intra-group transactions.

The framework within which these provisions operate is described on the Mauritius Revenue Authority (MRA) web page on the Domestic Minimum Top-up tax return. As that page puts it, the return is due no later than 15 months after the end of the fiscal year, with any tax paid at the same time; late payment attracts a penalty of 5 per cent of the unpaid tax and interest of 0.25 per cent per month; and an amended return cannot be submitted more than 2 years after the end of the relevant year of assessment. Read against those descriptions, the amendments start the 15-month period from the end of the month in which the fiscal year ends, halve the penalty, and extend the amendment window to three years. When we checked, the MRA page still showed the earlier figures.

The detailed computation rules are in the Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026 (GN No. 135 of 2026), published in the Government Gazette on 8 August 2026. They define an investment fund by a set of criteria, among them pooling investors' assets, following a defined investment policy and being managed by investment professionals.

Who is affected

According to the MRA's guidance note on QDMT tax notification, the tax applies to companies resident in Mauritius that belong to a multinational group with consolidated annual revenue of EUR 750 million or more in at least two of the four preceding fiscal years. A Mauritius-resident group company is designated to file.

The investment fund change is the one Mauritius funds and their holding vehicles should read closely. A fund, or a real estate investment vehicle, is an excluded person only when it stands at the top of the group as ultimate parent entity. Subsidiaries held by funds are not excluded by this provision.

Key dates

• 8 August 2026: QDMT Regulations 2026 gazetted, deemed in operation from 1 July 2025.
• 12 August 2026: Finance Act 2026 assented.
• EY's alert on the Act (17 September 2026) lists the first year of application of these amendments as the year of assessment 2025/2026. The commencement section of the Act was not legible in the version we reviewed, so we have not confirmed this on the Act itself.

What it means in practice

The penalty change is the easiest to measure. On a hypothetical EUR 1 million of top-up tax paid late, the penalty falls from EUR 50,000 to EUR 25,000, before interest.

The filing change matters mainly to groups whose fiscal year does not end on the last day of a month, such as those that use 52 or 53 week years. On the face of the amendment, a group whose year ends on 27 December 2025 would count its 15 months from 31 December 2025, so its return would fall due on 31 March 2027 and not on 27 March 2027.

The longer window for amended returns gives designated filers more time to correct positions as OECD guidance develops.

What we do not yet know

We could not find on the MRA website a QDMT tax guide dated September 2026, and the MRA's return page had not been updated for the Finance Act 2026 changes when we checked.