QDMTT in Mauritius: October 2026 update following the September deadlines

Oumme — Tue, 20 Oct 2026 10:46:41 +0000

The QDMTT regulations have been in force since August 2026 and apply retrospectively from 1 July 2025. It is now 7 October 2026. For some groups, the first deadline, 7 September, has already passed, while the next ones, 30 September and 31 December, are fast approaching. For businesses using GBCs or other Mauritian vehicles within an international group, it is no longer enough to focus on the general principles: an immediate review is required.

QDMTT in three key points

The QDMTT (Qualified Domestic Minimum Top-up Tax) is a mechanism designed to ensure that Mauritius collects locally the “top-up tax” due where a multinational group’s effective tax rate is below 15% in a given jurisdiction. In practice:

Who is affected?

The regime applies to multinational groups with consolidated revenue of at least €750 million in at least two of the four financial years preceding the financial year in question. Groups below this threshold are not subject to the QDMTT.

What is the principle?

If the effective tax rate of the group’s Mauritian entities is below 15%, a “top-up” is due under the QDMTT. The idea is for Mauritius to collect this top-up before other jurisdictions do so under their own Pillar Two rules.

Who files and pays?

A “designated person” within the group, notified to the Mauritius Revenue Authority (MRA), is responsible for filing the QDMTT return and making any payment due. This person may be a Mauritian entity within the group or a local representative, depending on the organisation chosen.

The specific 2026 deadlines

The August 2026 regulations set out a specific timetable, creating a genuine sense of urgency for certain groups:

Notification to the MRA: the designated person must be notified within 6 months of the end of the group’s financial year.
Filing of the return and payment of the QDMTT: within 15 months of the end of the group’s financial year.

Depending on the financial year-end, the first deadlines are in September and December 2026:

For groups whose financial year ended between January and May 2025, the notification deadline was 7 September 2026.
Other regulatory guidance and expectations point to deadlines around 30 September 2026 and 31 December 2026 for certain returns, certifications or initial payments, depending on the circumstances.

Even if your group is not yet within the scope of the QDMTT, these dates are a signal: the tax authorities and the FSC expect Mauritian structures to be ready to provide the necessary information (entities, income, governance and documentation).

What this means for GBCs and holding companies in Mauritius

For GBCs, Authorised Companies, trusts and other vehicles used within group structures, the QDMTT has several practical implications:

Mapping the Mauritian entities
The group’s tax advisers will need a clear list:
- of all Mauritian entities (GBCs, ACs, trusts, foundations, etc.);
- of their role within the group (holding, financing, trading, IP, etc.);
- of their relationship with the “Ultimate Parent Entity” and the Pillar Two reporting jurisdiction.
Tax and corporate documentation
The calculation of the effective tax rate and potential QDMTT relies on accurate financial and tax data. The teams handling Pillar Two will ask for:
- consistent financial statements;
- a description of intra-group flows;
- governance documentation (boards, resolutions and evidence of substance).

Poorly documented governance or outdated registers can complicate the advisers’ work and increase the risk of errors.

Interaction with other local taxes
The QDMTT adds to an already evolving tax landscape:
- a 15% standard corporate income tax rate;
- Fair Share Contribution for companies whose taxable income exceeds MUR 24 million;
- Alternative Minimum Tax (AMT) in certain sectors.

How these elements interact with the effective tax rate and top-up calculation must be assessed on a case-by-case basis.

“October 2026” checklist for groups

If your group may fall within the scope of the QDMTT, here is a minimum checklist for October 2026:

Have you identified the “Ultimate Parent Entity” and the Pillar Two reporting jurisdiction?

This is the starting point for understanding where global reporting takes place and how Mauritius fits into the framework.

Have you notified the “designated person” to the MRA (if the deadline has passed or is approaching)?

For financial years ending between January and May 2025, the notification deadline was 7 September 2026. If this has not been done, you need to act immediately with your tax advisers.

Have you started calculating the effective tax rate and potential QDMTT for 2025?

Tax advisers will need reliable data on the Mauritian entities. The more complete the corporate and tax documentation, the smoother the process will be.

Are your Mauritian structures “audit-ready”?

Up-to-date registers, board minutes, resolutions, beneficial ownership documentation and evidence of substance may all be requested to support the QDMTT work.

What C&S Secretarial Services can do to support your tax advisers

C&S is not a tax adviser, but can play a key role in supporting the teams handling the QDMTT:

Mapping of Mauritian entities: list and description of GBCs, ACs, trusts, foundations and other vehicles within the group.
Preparation of corporate documentation: registers, minutes, resolutions, evidence of governance and substance, ready to be provided to tax advisers.
Local coordination: liaison with Management Companies, auditors and other service providers to gather the necessary information on time.

Is your group potentially affected by the QDMTT and the September–December 2026 deadlines? Tell us about your Mauritian structure and we will help you prepare the corporate documentation for your tax advisers.

Editorial note: This article is a practical guide for directors, CFOs and compliance officers of multinational groups using structures in Mauritius. It does not replace specialised tax advice on the QDMTT, but aims to help businesses engage with their advisers on an informed basis.

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