The France-Mauritius tax treaty avoids double taxation. It allocates the right to tax between the two countries and provides, depending on the circumstances, for an exemption or a tax credit for cross-border income. If you are planning a trip, local support for living in Mauritius can help you outline the steps before the tax phase. (impots.gouv.fr)
The DGFiP website brings together the convention, the amendment of June 23, 2011 and the consolidated version modified by the multilateral convention; it is the safest starting point to check the applicable text. the official DGFiP fact sheet dedicated to Mauritius (impots.gouv.fr)
What the Franco-Mauritian convention actually says
The official consolidated version of the convention applies to residents of both states, to income taxes and to certain elements of wealth, including real estate. official consolidated version of the treaty (impots.gouv.fr)
The core issue is not to abolish taxation, but to prevent the same income from being taxed twice without coordination. The convention therefore establishes the allocation of the right to tax, and Article 24 describes how double taxation is eliminated. (impots.gouv.fr)
How to determine your tax residence between France and Mauritius?
The first question is always tax residence. The convention defines a resident as a person liable to tax in one of the States by reason of their domicile, residence, place of management or a comparable criterion; in the case of dual residence, an order of priority applies. tax doctrine on tax residence and conventions (impots.gouv.fr)
- The permanent residence is examined first. (impots.gouv.fr)
- If you have a home in both states, the center of your vital interests becomes decisive. (impots.gouv.fr)
- If not, we look at the usual residence in each country. (impots.gouv.fr)
- If doubt persists, nationality, followed by the agreement of the competent authorities, will resolve the matter. (impots.gouv.fr)
- For a company, the location of its effective management generally determines the decision. (impots.gouv.fr)
In practice, this hierarchy prevents a person from being considered simultaneously as a resident of both countries, thus reducing the risks of double taxation and reporting conflicts. (impots.gouv.fr)
What income is affected and how is double taxation avoided?
The convention covers a wide range of cross-border income: business profits, dividends, interest, royalties, capital gains, salaries, self-employment income, pensions, and public office income. Article 24 then specifies whether Mauritius grants an exemption, whether France applies a tax credit, or whether taxation remains concentrated in a single state. (impots.gouv.fr)
Summary table of main incomes
| Income | Main rule | Key points to remember |
|---|---|---|
| Salaries and wages | Taxable in the state where the employment is performed, except in certain cases where the stay does not exceed 183 days, the employer is not a resident of the other state, and the expense is not borne by a permanent establishment or fixed base in that other state. (impots.gouv.fr) | Useful for short-term assignments, secondments, and certain teleworking arrangements. (impots.gouv.fr) |
| Independent professionals | Taxable only in the state of residence, unless the professional ordinarily has a fixed base in the other state. (impots.gouv.fr) | The actual location where the business activity is carried out can affect taxation. (impots.gouv.fr) |
| Business profits | Taxable in the country of residence, unless the business operates in the other country through a permanent establishment. (impots.gouv.fr) | Profits attributable to local presence become taxable locally. (impots.gouv.fr) |
| Dividends | Taxable in the country of residence and also in the country of origin, with withholding tax capped at 5% if the beneficiary company holds at least 10% of the capital, otherwise 15%. For a resident of France receiving dividends from Mauritius, the treaty provides for a tax credit equal to 25% of the gross amount. (impots.gouv.fr) | The tax treatment depends on the country of origin, the beneficial owner, and the shareholder's status. (impots.gouv.fr) |
| Interests | Taxable in the country of residence and also in the country of origin, with an exception for certain interest paid to a state, a public body or a banking institution of that state. (impots.gouv.fr) | For a resident of France, Mauritian tax entitles them to a tax credit under the conditions of Article 24. (impots.gouv.fr) |
| Royalties | Taxable in the country of residence and may be taxed in the country of origin, up to a limit of 15% of the gross amount. (impots.gouv.fr) | France generally grants a tax credit against Mauritian tax, up to the amount of French tax owed. (impots.gouv.fr) |
| Capital gains | Capital gains from real estate are taxable in the state where the property is located; gains from assets used in a permanent establishment or fixed base follow the same rule. Other capital gains are generally taxable in the state of residence. (impots.gouv.fr) | Asset transfers must be assessed on a case-by-case basis, especially for real estate and securities related to real estate. (impots.gouv.fr) |
| Pensions | Pensions from previous employment are generally taxable in the country of residence; social security pensions are taxable in the country that pays them. (impots.gouv.fr) | Always verify the exact origin of the pension before concluding that it is exempt. (impots.gouv.fr) |
Public income and certain civil service pensions are still subject to specific rules set out in Article 19, which can change the competent country depending on the nature of the service rendered and the beneficiary's residence. (impots.gouv.fr)
The basic scheme is simple: the source country can tax certain income, the country of residence avoids double taxation through exemptions or credits, and certain categories benefit from specific ceilings. (impots.gouv.fr)
Concrete examples to better understand
Employee sent to Mauritius for a short assignment
If a French employee goes to work in Mauritius for a few months, the 183-day exception may allow them to remain taxed only in their country of residence, provided that the employer is not resident in the other country and that the cost of the salary is not borne by a local permanent establishment. Conversely, if the work is actually performed in Mauritius and the conditions are not met, Mauritius may tax the salary. (impots.gouv.fr)
Consultant, entrepreneur or company with local operations
A consultant, freelancer, or company must primarily monitor the existence of a fixed base or permanent establishment. As soon as a local presence becomes sufficiently structured, the portion of profit attributable to that presence may be taxed in the other country. This is often the factor that most significantly impacts the tax bill when setting up or starting a business. (impots.gouv.fr)
Investor receiving dividends or interest
For dividends and interest, the mechanism is different: the source country may withhold tax, but the tax treaty regulates this withholding, and France may then grant a tax credit. For a French resident receiving Mauritian dividends, the specific treaty credit of 25 % is a point to verify before making any investment decision. (impots.gouv.fr)
Points to consider before relying on the convention
The convention, as amended by the multilateral convention, also contains an anti-abuse safeguard: a treaty benefit may be denied when it appears that one of the main objectives of an arrangement was to obtain it, unless the benefit remains consistent with the object and purpose of the text. In other words, a structure is not only valid on paper; it must also be economically and fiscally sound. (impots.gouv.fr)
To prepare your application and anticipate the necessary steps, practical guides to help you prepare your installation can be a good entry point.
To verify the site's legal framework and the publisher's identity, you can also consult the website's legal notices.
FAQ on the France-Mauritius tax treaty
How to avoid double taxation between France and Mauritius according to the Franco-Mauritian convention?
Start by identifying your tax residence, then determine the income category. The treaty avoids double taxation in two ways: either one of the states exempts the income, or it taxes it while granting a tax credit for the tax paid abroad. In practice, income taxed in Mauritius is not treated the same way depending on whether it is a salary, a dividend, interest, or a royalty. The best approach is therefore to link each income stream to the correct treaty article. (impots.gouv.fr)
What income is covered by the France-Mauritius tax treaty and how is it taxed?
The convention covers income from salaried employment, business profits, self-employment, dividends, interest, royalties, capital gains, pensions, and public office. It also addresses certain assets, particularly real estate. This means that the convention applies not only to investors, but also to employees, freelancers, and executives who have economic ties between the two countries. (impots.gouv.fr)
How to determine your tax residence between France and Mauritius to avoid double taxation?
First, each country's internal rules are applied, then the convention addresses cases of dual residence. For individuals, the order is as follows: permanent home, center of vital interests, habitual residence, nationality, then agreement between competent authorities. For a company, the place of effective management is the determining factor. This point is crucial, as it determines the right to tax and the mechanisms for tax credits or exemptions. (impots.gouv.fr)
How does the tax credit work when tax is paid in Mauritius for a tax resident in France?
When tax has already been paid in Mauritius, France may grant a tax credit on certain income from Mauritius. For interest, royalties, self-employment income, and other income covered by Article 24, the credit generally corresponds to the Mauritian tax paid, without exceeding the French tax due on the same income. For Mauritian dividends paid to a resident of France, the tax credit is specific and amounts to 25% of the gross amount. (impots.gouv.fr)
Does the France-Mauritius convention include specific provisions for dividends and interest?
Yes, and they are very important. Dividends can be taxed in both the source country and the country of residence, but withholding tax is capped at 5% or 15% depending on the beneficiary's situation. Interest is also subject to regulations, with exemptions for certain public or banking beneficiaries. For an investor or executive, these details can significantly impact the net return on a transaction. (impots.gouv.fr)
And now ?
If you want to take your project further, the Help page for expatriation to Mauritius in English It allows you to quickly identify useful support services for initial planning. It is particularly useful if you wish to structure your setup, residence, or investment project before finalizing your tax strategy.
