Transfer Pricing in Mauritius: The Arm’s-Length Standard
How Mauritius applies transfer pricing principles to related-party transactions and how to document them defensibly.
Mauritius applies the arm’s-length principle to cross-border and domestic related-party transactions. MRA may adjust profits where transactions are not on arm’s-length terms, and the burden of proof sits with the taxpayer.
Documentation
Maintain a functional analysis, benchmarking study, intercompany agreements and evidence of actual conduct. GBCs are particularly exposed given typical intra-group financing and management-fee flows.
Methods accepted
OECD-aligned methods including CUP, resale price, cost plus, TNMM and profit split. Selection depends on functions performed, assets used and risks assumed.
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