Double taxation: you can quickly end up paying twice for the same income between France and Mauritius.
There France-Mauritius tax treaty (double taxation treaty) sets out clear rules for determining which country has the right to impose (France or Mauritius) depending on the type of income (salaries, dividends, rents, pensions, etc.) and how the other country should neutralize double taxation (tax exemption or credit). (mra.mu)
In this article, you will find a practical read (without unnecessary jargon) of the points that really matter to expats, retirees, investors and entrepreneurs with interests in both countries.
Important : This article is for general informational purposes only. Tax treaties always interact with domestic law (France/Mauritius) and your personal circumstances (residence, household, legal structure, etc.). If there are significant implications, consult a professional.
What is the purpose of the France-Mauritius tax treaty (in concrete terms)?
The convention has three main objectives:
- Distribute the right to tax For example, rent is generally taxed in the country where the property is located, while certain financial income may be taxed in both countries but with a cap on withholding tax.mra.mu)
- Avoiding double taxation either via exemption, either via tax credit (central mechanism of the convention). (mra.mu)
- Strengthen cooperation : exchange of information between administrations (particularly after the 2011 amendment), and since the entry into force of the MLI (OECD Multilateral Instrument), addition of anti-abuse tools (principal purpose test).legifrance.gouv.fr)
Key dates and official documents to know
The tax treaty between France and Mauritius has been signed on December 11, 1980 in Port Louis, and is entered into force on September 17, 1982. (bofip.impots.gouv.fr)
She was amended by an addendum signed on June 23, 2011, which entered into force on May 1, 2012 (particularly regarding the exchange of information).bofip.impots.gouv.fr)
Finally, the convention is impacted by the MLI (OECD – BEPS). The "summarized" text published by the Mauritius Revenue Authority specifies, in particular, different effective dates depending on the nature of the taxes (withholding taxes vs. other taxes).mra.mu)
Useful resources (texts and administrations):
- Summarized text (MLI + convention) published by the Mauritius Revenue Authority : France/Mauritius – Synthesised text (PDF). (mra.mu)
- Reference in France (BOFiP): France-Mauritius Tax Convention. (bofip.impots.gouv.fr)
Step 1: Determine your tax residence (the starting point)
To apply the convention, you first need to know where you are. resident for tax purposes. The convention defines a "resident of a State" as a person taxable in that State by reason of their domicile, residence, place of residence, etc.mra.mu)
In the case of dual residence: the “tie-breakers” of the convention
If, according to domestic law, you can be considered a resident on both sides, the convention makes the distinction according to a cascading logic:
- permanent residential home; ;
- center of vital interests (personal and economic ties); ;
- usual place of residence; ;
- Nationality ;
- agreement between administrations if necessary.mra.mu)
For companies: “place of effective management”
For a non-individual entity, the convention generally considers the State where the place of effective management. This can become crucial if you are managing a Mauritian company from France (or vice versa).mra.mu)
Step 2: Identify the nature of the income (and the state that has the right to tax it)
The right reflex: categorize income (salary, dividends, real estate…) then apply the corresponding article of the agreement.
Summary table (quick read)
| Type of income | Principle of taxation according to the convention | Withholding tax ceiling (if applicable) | Point of attention |
|---|---|---|---|
| Wages (salaried employment) | Taxation in the state where the employment is performed, with the exception of the “183 days” rule.” | – | Length of service + employer + rebilling/charge by a permanent establishment |
| Company profits | Taxation in the state of residence, except permanent establishment in the other state | – | Construction site > 6 months = permanent establishment (as a general rule) |
| Real estate income (rents) | Taxation may be possible in the state where the property is located. | – | Declaration in France even if exempt via “effective rate” depending on the case |
| Dividends | Taxable in the state of residence, and also in the source state | 5% (direct participation ≥ 10%) / 15% (other cases) | Concept of beneficial owner + formalities to apply the reduced rate |
| Interests | Taxable in the state of residence; the source state may also tax according to its law. | No overall cap; source exemption possible for certain beneficiaries (state, public body, bank) | Specific cases (banks/public bodies) = exclusive taxation in the state of residence |
| Royalties | Taxable in the state of residence, and also in the source state | 15% max (if beneficial owner) | Verify the qualification (royalties vs services) |
| Private guesthouses | Taxation is generally in the state of residence. | – | Different for social security pensions |
| Social security pensions | Exclusive taxation in the paying state (under its social legislation) | – | Important for French pension received from Mauritius |
| Capital gains (real estate / securities) | Real estate: Status of assets; other assets: Status of residence (with protocol exceptions) | – | Case of companies with a predominantly real estate portfolio and “substantial interest” |
Wages: Where is the work performed? (183-day rule)
Salary from salaried employment is taxable in the state of residence except if the employment is performed in the other State. An exception protects short-term assignments: if you stay ≤ 183 days (in the relevant tax year), the employer is not a resident of the State where the employment is performed, and there is no expense borne by a permanent establishment, taxation remains in the State of residence.mra.mu)
Self-employed/liberal professions: the “fixed base”
Income from self-employment is generally taxable in the state of residence., except if you have a fixed base (office, practice, etc.) in the other State, in which case that other State may tax the portion attributable to that fixed base.mra.mu)
Entrepreneurs: permanent establishment (PE) and the 6-month rule
Regarding corporate profits, the other state can only tax if there is a permanent establishment (PE). The convention considers, in particular, that a construction site/building/installation constitutes a PE if it lasts more than 6 months. (mra.mu)
Real estate (rents): the state where the property is located has control
Income derived from real estate (rental, operation, agriculture/forestry) located in another state may be taxed in the state where the real estate is located.mra.mu)
Dividends: Withholding tax ceilings 5% / 15%
The convention caps the withholding tax on dividends at:
- 5% if the beneficial owner is a company (excluding partnerships) directly holding at 10% of capital,
- 15% in other cases. (mra.mu)
Interest: be aware, there is no general maximum rate
The convention stipulates that interest may be taxed in the state of residence, and can also to be taxed in the source state “according to its law”. On the other hand, when interest is paid to the state, a public body, or a banking institution of the state of residence (and the recipient is the beneficial owner), taxation may become exclusive in the state of residence. (mra.mu)
Royalties: cap 15%
Royalties may be levied in the source state, but the rate must not exceed 15% of the gross amount if the beneficiary is the beneficial owner.mra.mu)
Pensions: distinguishing between “private pensions” and “social security”
Private pensions (retirement linked to a previous job) are generally taxable. in the state of residence. However, pensions paid under the social security of a State are taxable only in this state. (mra.mu)
Capital gains: general rules + important exceptions
The agreement notably provides for:
- Capital gains on real estate: taxable in the state where the property is located; ;
- capital gains on other assets: taxable in principle in the State of residence; ;
- exceptions via the protocol, particularly for certain real estate-related securities and the concept of substantial interest (defined as 25% or more of the company's profits, according to the text).mra.mu)
Step 3: How the convention eliminates double taxation (exemption vs. tax credit)
The convention provides for a method for eliminating double taxation which combines:
- Exemption in the state of residence for certain income taxable in the other state,
- Tax credit For other income: the tax paid in the source state is credited (within certain limits) against the tax due in the state of residence.mra.mu)
What this changes for you (on-the-ground version)
If you are a tax resident of France and receive income from Mauritian sources, you will often have to declare them in France (foreign income form), then apply either an exemption or a tax credit, depending on the category and what the treaty stipulates. Official tax websites reiterate the principle: tax paid abroad is generally not "deducted" from income, but entitles the taxpayer to a tax credit. tax credit deductible from French tax, according to the convention.impots.gouv.fr)
If you are a tax resident of Mauritius With income from French sources, the mechanism also depends on the category: some income may be exempt in Mauritius if it is taxable in France, while other income gives rise to a tax credit in Mauritius up to the limit of the Mauritian tax attributable.mra.mu)
Step 4: How to “activate” the agreement in real life (documents and procedures)
1) Prove your tax residence (otherwise, no reduced rate)
In practice, the administration/payer will apply domestic law “by default” until you have proven your tax residence. In Mauritius, obtaining a Tax Residence Certificate (TRC) This is done via the MRA (International Taxation Unit) system. (eservices3.mra.mu)
2) Reducing withholding tax in France: forms 5000/5001
For income from French sources (particularly distributed income), the procedure frequently involves using forms. 5000-SD (proof of residence) and 5001-SD (depending on the nature of the income). The BOFiP explicitly mentions these forms in the context of withholding tax procedures.bofip.impots.gouv.fr)
3) Declare correctly (France)
If you remain a French tax resident with Mauritian income, the tax authorities remind you that you must detail your foreign income using the dedicated annex, then transfer this information to your main tax return.impots.gouv.fr)
4) Filing taxes correctly (Mauritius): recent tax guidelines (2025/26)
The convention avoids double taxation, but does not replace Local taxation. In Mauritius, the personal income tax system has evolved: the MRA indicates that new rates and brackets are effective from July 1, 2025 (0% on the first Rs 500,000, 10% on the next Rs 500,000, then 20% beyond that), and also mentions a Fair-Share Contribution for high incomes.mra.mu)
Common points to consider (costly mistakes)
The agreement does not cover everything (e.g., social security contributions)
A tax treaty covers income tax/corporate tax (and certain related taxes). Some contributions or levies (depending on their legal classification) may be treated differently. In sensitive situations (pensions, investment income, etc.), a case-by-case review is essential.
Year of departure/return: specific declarations on the French side
In the event of departure abroad, the French administration specifies that there may be particular reporting obligations (income from the period of departure, post-departure French-source income, non-resident tax office, etc.).impots.gouv.fr)
Exchange of information (2011 amendment): no more banking “grey area”
The 2011 amendment strengthened the article relating to the’exchange of information The text stipulates that government departments may exchange information that is “likely relevant,” and that the exchange cannot be refused solely on the grounds that the information is held by a bank or financial institution.legifrance.gouv.fr)
Anti-abuse (MLI): the “Principal Purpose Test” (PPT)
Since the integration of MLI clauses, a benefit under a collective agreement can be denied if it is reasonable to conclude that obtaining that benefit was one of the main objectives of a setup or transaction (anti-“treaty shopping” logic).mra.mu)
Concrete examples to help you find your way (without “false promises”)
Example 1 — Dividends France → Mauritius: capped withholding tax
You are a Mauritian tax resident and receive 10 000 € of dividends from a French company. If you are the beneficial owner and if you directly hold at least 10% of capital, the withholding tax (on the French side) is capped at 5%, or at most 500 €. If you do not meet the participation requirement, the limit increases to 15% (max 1 500 €Next, taxation in Mauritius and any potential tax credit depend on your local rules and your situation.mra.mu)
Example 2 — Royalties: 15% cap at source
You charge a royalty (license, trademark, patent, etc.) of 20 000 € to a client in the other state. The convention allows for withholding tax, but the rate is capped at 15% of the gross amount if you are the beneficial owner (i.e., max 3 000 € (withholding tax). Here again, the way to avoid double taxation is through the mechanism provided (often a tax credit) depending on the state of residence.mra.mu)
Example 3 — Short-term assignment (employee): the 183-day rule
You are a tax resident of Mauritius, employed by a Mauritian company, and you are working temporarily in France. 120 days for the fiscal year. If the remuneration is not paid through a permanent establishment in France and if the employer is not a resident of France, the treaty may assign taxation solely to the State of residence (logic of 183 daysNote: the facts (contract, rebilling, actual place of business, etc.) are decisive.mra.mu)
Example 4 — Retirement: private pension vs. social security pension
Two treatments can coexist: one private guesthouse (e.g., company pension) is in principle taxable in the state of residence; a pension covered by social security Income from a state is taxable only in that state. A retiree living in Mauritius may therefore have a portion taxable in Mauritius and another portion taxable in France, depending on the exact nature of the pensions.mra.mu)
FAQ — France-Mauritius Tax Treaty: Frequently Asked Questions
How to avoid double taxation on dividends between France and Mauritius?
The logic unfolds in two stages. First, the convention caps the withholding tax in the payer's state (for example 5% or 15% (on dividends, subject to the conditions). Then, in your country of tax residence, you declare the dividends and apply the mechanism designed to neutralize double taxation (often a tax credit within certain limits). In practice, you also need to "activate" the treaty by providing proof of tax residence; otherwise, the reduced rate may not be applied automatically.
If I live in Mauritius, do I still need to declare anything in France?
Yes, potentially. Even as a non-resident, you may still be taxable in France on certain income. income from French sources (e.g., real estate located in France, certain professional income, etc.), according to the agreement and domestic law. The French tax authorities also specify obligations for the year of departure (forms/attached documents, departure period, French-source income after departure, etc.). The key is to distinguish tax residence And source of income : changing country of residence does not automatically eliminate all tax ties with France.
How to obtain a Tax Residence Certificate (TRC) in Mauritius?
The Tax Return Certificate (TRC) serves as proof of your Mauritian tax residency to benefit from the advantages of a tax treaty (reduced rates, tax credits, etc.). The Mauritius Revenue Authority (MRA) provides an online filing system and a dedicated contact point through its International Taxation Unit. The required documents and conditions vary depending on your profile (individual, company, period concerned, etc.). It's best to plan ahead: without a TRC/proof of residency, the foreign taxpayer can apply the default withholding tax, and you will then have to rectify the situation.
Does the tax treaty also protect against the automatic exchange of information?
No: on the contrary, modern texts move towards enhanced cooperation. The 2011 amendment replaced the article on the exchange of information and stipulates that information "likely to be relevant" can be exchanged, and that the exchange cannot be refused solely on the grounds that the information is held by a bank or financial institution. In practice, this means that a strategy based on opacity is risky and increasingly untenable; it is better to structure properly and report correctly.
Does the France-Mauritius convention prevent double taxation on real estate in France?
The convention generally grants the right to tax real estate income (and often capital gains on real estate) to the state where the property is located. Therefore, a resident of Mauritius who rents out a property in France may be taxed in France on that income. Simultaneously, depending on the rules of the resident's country of residence, the income may also need to be declared, but with a mechanism to eliminate double taxation (exemption or credit). In some cases, filing a tax return in France remains necessary even if a mechanism neutralizes the tax liability in the other country.
And now ?
If you are preparing for expatriation, investment, or the creation of a business in Mauritius, the tax implications must be addressed. at the same time Visa/permit, accommodation, school, banking, and structuring your project. Expat Mauritius can assist you with settling in and the "turnkey expatriation" aspect, and direct you to the right contacts when tax matters become complex: discover the support available at [website address]. Expat Mauritius, the “installation & real estate” solutions via Living in Mauritius: turnkey expatriation and real estate, and practical resources on Expatriation guides.
