Australia Mauritius Double Tax Agreement: A Complete Guide
What Is the Australia-Mauritius DTA?
The Double Tax Agreement between Australia and Mauritius entered into force in 1992. It establishes the framework for taxation of cross-border income between residents of the two countries. Mauritius has become a significant international financial centre, and the DTA is relevant for Mauritius-based Australian expats, Mauritius Global Business Companies (GBC) with Australian investments, and high-net-worth individuals who have relocated to Mauritius under the country's premium visa and residency schemes.
Mauritius operates a territorial tax system for individual residents in many circumstances, and has low tax rates broadly: a flat personal income tax rate of 15% on taxable income (with certain exemptions), no capital gains tax, and no inheritance tax. For Australian property investors based in Mauritius, this creates a favourable tax position: Australia taxes Australian-source income, Mauritius may tax some of the same income at low rates or not at all, and the DTA provides credit relief where both countries' tax applies.
The Mauritius Revenue Authority (MRA) administers income tax at a flat rate of 15%. Mauritius does not impose CGT on capital gains of any kind — including gains on foreign property. This makes Mauritius one of the most tax-efficient residency jurisdictions for Australian property investors from a capital gains perspective.
How the Credit Mechanism Works
The Australia-Mauritius DTA operates on a credit mechanism. Australia taxes Australian-source income first at non-resident rates. Mauritius then taxes the same income under its domestic regime, but grants a credit for Australian tax paid to the extent Mauritius imposes tax on the same income.
For rental income: Mauritius taxes worldwide income of Mauritius residents at 15% flat. Australian non-resident rental income rates (32.5-45%) substantially exceed the Mauritius rate. The DTA credit for Australian tax paid fully covers the Mauritius tax liability on the same rental income — no additional Mauritius tax payment is required in practice.
For capital gains: Mauritius imposes no CGT at all. You pay Australian CGT only on Australian property gains. No Mauritius tax applies, no credit is needed, and no Mauritius filing is required for the gain. This is a clean, single-jurisdiction CGT position.
Real Property Income
Australian rental income earned by Mauritius residents is taxed primarily by Australia under the DTA. Non-residents pay Australian tax on net rental income at non-resident rates (32.5-45%) with no tax-free threshold. Deductible expenses include mortgage interest, land tax, council rates, insurance, maintenance, and property management fees.
Mauritius residents must report worldwide income in their Mauritius income tax return, but the DTA credit for Australian tax paid eliminates any additional Mauritius tax on the same income. In practice, Australian rental income creates no net Mauritius tax obligation for investors already paying Australian non-resident rates.
Capital Gains on Australian Property
Australia has primary taxing rights on gains from Australian real property. Non-residents pay Australian CGT on 100% of the gain at marginal rates — the 50% discount does not apply. Mauritius does not impose any capital gains tax on foreign property. There is no Mauritius tax on Australian property gains, no DTA credit calculation needed, and no Mauritius filing requirement for the gain.
This is one of the cleanest capital gains tax positions available for an Australian property investor: pay Australian CGT, and the obligation ends there. No dual-filing, no credit mechanics, no second jurisdiction's tax to manage on the same gain.
Foreign Resident Capital Gains Withholding (FRCGW) applies for Australian property sales of AUD 750,000 or higher. 12.5% of the net sale price is withheld at settlement as a payment on account of Australian CGT. This is the only withholding you need to track — there is no Mauritius equivalent.
Dividend Withholding Rates
Under the Australia-Mauritius DTA, dividends paid by Australian companies to Mauritius residents are subject to a maximum withholding rate of 15%. The standard Australian non-resident withholding rate is 30%. The DTA provides a significant saving. Mauritius also taxes dividend income at 15% flat, but the DTA credit for Australian withholding tax reduces any additional Mauritius liability.
Interest and Royalty Withholding Rates
Interest paid from Australia to Mauritius residents is subject to a maximum withholding rate of 10% under the DTA. Royalties are subject to a maximum withholding rate of 10% under the DTA, significantly lower than the standard 30% non-resident withholding rate.
Mauritius Global Business Companies and Australian Investments
Mauritius Global Business Companies (Category 1 and 2, now Category 1 GBC under the reformed regime) are used extensively for international investments. GBCs holding Australian property may access DTA benefits, including reduced withholding rates on dividends and interest. However, GBC structures have specific substance requirements and tax residency conditions under Mauritius law. The Australian Tax Office also scrutinises structures using Mauritius entities to access DTA benefits. Seek specialist advice if considering a GBC structure for Australian property investment.
Filing Obligations
Australian filing: Lodge an Australian income tax return by 31 October each year for any assessable Australian income. A registered tax agent extends this to 15 May the following year.
Mauritius filing: Report worldwide income in your Mauritius annual income tax return (AIT). Given the flat 15% rate and DTA credit for Australian tax, net Mauritius tax on Australian-source income is typically nil. No Mauritius return is required for capital gains since Mauritius has no CGT.
How ODIN Tax Can Help
ODIN Tax specializes in Australian property tax for international investors including Mauritius-based clients. We lodge your Australian returns, claim all available deductions, manage land tax and FRCGW compliance, and provide documentation for your Mauritius adviser. We understand the favourable Mauritius tax position for Australian property investors — particularly the absence of Mauritius CGT — and help you manage Australian compliance efficiently. Our TAN is 26295891. Contact us for specialist advice.
FAQs
Does Mauritius impose capital gains tax on Australian property gains? No. Mauritius has no capital gains tax regime. Gains from Australian property are not taxable in Mauritius. You pay Australian CGT only.
What is Mauritius's personal income tax rate? A flat rate of 15% on taxable income for individual residents. Significantly lower than Australian non-resident rates (32.5-45%).
What is the dividend withholding rate under the Australia-Mauritius DTA? 15% maximum, compared to the standard 30% non-resident withholding rate.
Can Mauritius residents claim the Australian 50% CGT discount? No. The discount applies only to Australian residents. Non-residents pay CGT on 100% of the gain.
What is the FRCGW withholding rate? 12.5% of the net sale price for Australian property sales of AUD 750,000+ by foreign residents. Payment on account of Australian CGT only. No Mauritius equivalent applies.
This guide is general information only and does not constitute personalised tax advice. Tax law is complex and your circumstances matter significantly. Consult a licensed tax agent before making investment decisions. ODIN Tax is regulated by the ATO (TAN 26295891) and ASIC. This information is current as at April 2026.
