Key Takeaways
- A TIEA governs tax information exchange on request, unlike a double tax agreement that mainly allocates taxing rights and relieves double taxation.
- Mauritius limits disclosure under defined confidentiality safeguards, so shared information is tied to a specific tax purpose rather than open access.
- Non-resident owners and advisers should understand how an exchange request is made and processed, since records held in Mauritius can be reached lawfully.
- These agreements align Mauritius with OECD global transparency standards, shaping the outlook for future information exchange.
What a TIEA Is and Why Mauritius Signed Them
A Tax Information Exchange Agreement (TIEA) is a bilateral instrument whose single purpose is to let two governments share tax-relevant information on request. Mauritius operates a network of TIEAs alongside its broader tax treaty network, with the Mauritius Revenue Authority (MRA) acting as the competent authority for all exchange-of-information matters.
These agreements matter to any foreign owner, investor, or adviser connected to a Mauritius structure whose home tax authority may one day ask the MRA for information. This article explains what TIEAs in Mauritius cover, how a request works, the confidentiality limits that apply, and where these bilateral tools sit within the wider transparency framework.
The reader most affected is a non-resident who holds, or advises a client who holds, a Global Business Licence company, trust, foundation, or authorised company on the island.
The Difference Between a TIEA and a Double Tax Agreement
A TIEA does one thing: it enables the exchange of tax information. It contains no rate schedules, grants no treaty benefits, and carries none of the relief provisions found in a full tax treaty.
A Double Tax Avoidance Agreement (DTAA) goes much further. It allocates taxing rights between two states and usually includes an information-exchange clause modelled on Article 26 of the OECD Model Tax Convention as one provision among many.
The practical distinction is straightforward for a foreign owner. A DTAA partner state receives both treaty benefits and an exchange mechanism; a TIEA partner receives the exchange mechanism alone.
Both routes serve the same transparency standard. The OECD's exchange-of-information-on-request (EOIR) benchmark asks that information "foreseeably relevant" for tax purposes, including the identity of legal and beneficial owners of assets, companies, and accounts, be available and accessible to a tax authority that can then share it under an international agreement.
| Feature | TIEA | DTAA |
|---|---|---|
| Allocates taxing rights | No | Yes |
| Treaty benefits (reduced withholding, relief) | No | Yes |
| Information exchange | Yes, sole purpose | Yes, via Article 26-style clause |
| Rate schedules | None | Included |
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Mauritius TIEA Network: How Many and With Which Partners
Eleven TIEAs are in force as at February 2026. The network is deliberately narrow when set against the 45 tax treaties the country has concluded.
The agreement with the United States dates from 2014, signed together with an Inter-Governmental Agreement to implement FATCA. The remaining ten partners span Europe, the Asia-Pacific, and several autonomous territories.
| Region | Partner jurisdictions |
|---|---|
| Americas | United States |
| Europe | Austria, Denmark, Finland, Iceland, Norway |
| Nordic territories | Faroe Islands, Greenland |
| Crown dependency | Guernsey |
| Asia-Pacific | Australia, South Korea |
The TIEA with Australia, signed in Port Louis on 8 December 2010, provides for exchange of information on request in both criminal and civil tax matters. It follows the standard OECD model formulation.
Three further agreements, with Argentina, Greece, and the Isle of Man, await signature. The MRA hosts the consolidated TIEA list on its International Taxation pages, alongside the longer DTAA schedule.
The Legal Basis for Information Exchange Under Mauritian Law
Domestic authority for these arrangements flows from Section 76 of the Income Tax Act 1995. It permits the Minister of Finance to enter into arrangements either for relief from double taxation or for the exchange of information to assist in administering tax laws of every kind.
Once such an arrangement is made, the usual secrecy duties under the revenue laws cannot stop the Director-General from disclosing the information the agreement requires, and only to an officer authorised by the partner government. The disclosure gateway is precise, not open-ended.
International agreements do not become binding domestically on signature alone. Mauritius follows a dualist approach, so a treaty or TIEA takes the force of law only once it is expressly incorporated and duly ratified.
The FATCA framework illustrates the mechanics. Its implementing regulations were published in the Government Gazette of 5 July 2014 and made under Section 76 of the same Act.
Two multilateral layers reinforce the bilateral ones. The country signed the OECD Convention on Mutual Administrative Assistance in Tax Matters in June 2015 and sits within the OECD G20 Inclusive Framework on BEPS, both administered domestically through the MRA, the statutory body created under the Mauritius Revenue Authority Act 2004.
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Scope of Information Covered by a Mauritius TIEA
A TIEA reaches further than basic registration data. The framework allows exchange of ownership information and material held by banks and financial institutions, subject to confidentiality safeguards.
The OECD 2002 Model TIEA, which shapes the local agreements, covers four categories:
- Identity and ownership of legal entities
- Banking information
- Accounting records
- Information held by nominees, trustees, and other intermediaries
For a foreign owner, the consequence is direct: beneficial ownership and account details are within scope, not merely the public register entry.
The FATCA arrangement is broader still in form, allowing exchange on request, spontaneously, and automatically between the island and the United States. That agreement also lists exempt beneficial owners and deemed-compliant entities, such as governmental bodies, international organisations, central banks, certain retirement funds, and qualified credit card issuers.
Country-by-Country Reporting, implemented in line with BEPS Action 13, forms a separate but related channel for large multinational groups.
How an Exchange-of-Information Request Works in Practice
The competent authority for every exchange matter is hosted at the MRA, which names the designated officer and authorised representatives on its website. A foreign tax authority routes its request through that single point.
Where fraud or evasion is suspected, the MRA can investigate and demand information from an individual or company. Its powers extend to site visits, access to records, and collection of documents after formal request.
- A treaty or TIEA partner's competent authority submits a request to the MRA.
- The MRA gathers the information from the relevant taxpayer, financial institution, or intermediary.
- The MRA verifies the request meets the agreement's terms, then transmits the data to the requesting authority.
The ordinary three-year window for audits and assessments does not constrain the MRA in fraud and evasion cases. Its Fiscal Investigations Department collects evidence and can recommend prosecution.
For the automatic channels, financial institutions report directly to the MRA. FATCA filings are passed onward to the US Internal Revenue Service, while CRS reports are encrypted and sent to partner authorities through secured file transfer.
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Confidentiality Safeguards and Limits on Disclosure
The disclosure power is bounded. Under the Income Tax Act, the Director-General may override domestic secrecy only to the extent a specific arrangement requires, and only to an officer authorised by the partner government.
Every MRA officer takes an oath of fidelity and secrecy and must keep confidential any matter learned on duty. The MRA's CRS Guidance Notes confirm that the island will exchange information only with jurisdictions that have proper confidentiality frameworks in place.
Information shared under the OECD model may be used only for tax purposes in the receiving country and may not be passed to a third state without consent.
The Global Forum peer review process tests these protections directly, assessing the country under Element C.3 on confidentiality and Element C.4 on the rights and safeguards of taxpayers and third parties. The OECD's 2014 supplementary findings recorded no concerns raised by peers over the handling of exchanged information.
How TIEAs Fit the OECD Global Transparency Standards
Bilateral TIEAs are one layer of a wider structure. They sit alongside Article 26 clauses in the DTAAs, the multilateral Convention on Mutual Administrative Assistance, automatic exchange under the CRS, and the FATCA Inter-Governmental Agreement.
Automatic exchange began in 2018, following signature of the multilateral convention in June 2015. The country is a signatory to the CRS, a member of the OECD Global Forum, and a party to the MLI to counter base erosion and profit shifting.
The published ratings are strong. A 2014 Global Forum review found the island Largely Compliant with the EOIR standard, and the 2017 Second Round report upgraded the overall rating to Compliant, the highest grade the Global Forum awards.
What a TIEA Means for a Non-Resident Owner or Adviser
If your home jurisdiction has a TIEA with the island, expect that the MRA can answer a specific information request from your home tax authority. For a GBL company, trust, foundation, or authorised company, that request can reach beneficial ownership and account data.
The eleven TIEA partners define where a formal on-request channel exists. An adviser whose client is resident in one of those states should plan on the assumption that the request route is open and functional.
Two structural points affect which network applies:
- A GBL company is resident for treaty purposes only if it holds a Tax Residency Certificate, obtained from the MRA on application via the Financial Services Commission.
- An authorised company is treated as non-resident for tax purposes, placing it outside DTAA protection but still within CRS and TIEA reach.
The bilateral count understates exposure. Even where neither a TIEA nor a DTAA covers a home jurisdiction, that country may still reach the island through the Multilateral Convention on Mutual Administrative Assistance, joined in 2015.
A more important reality for most non-residents is automatic exchange. Financial account data already flows to home jurisdictions under the CRS and FATCA without any formal request being lodged.
Outlook for Mauritius TIEAs and Information Exchange
The pipeline holds three unsigned agreements, with Argentina, Greece, and the Isle of Man. Beyond those, no formal government roadmap for new bilateral TIEAs is publicly documented.
The practical direction favours multilateral channels over fresh bilateral instruments. CRS automatic exchange, FATCA, and the multilateral convention together reach far more jurisdictions than eleven TIEAs ever could.
Operational investment continues. The Global Forum Secretariat and the MRA ran a workshop on verifying financial institutions' CRS compliance in September 2024, and the Pillar Two qualified domestic minimum top-up tax, effective 1 July 2025, will deepen reporting obligations for multinational groups.
Conclusion
For a non-resident connected to a Mauritius structure, the eleven TIEAs in force are only part of the picture. They open a formal on-request channel for a defined set of partner states, while the CRS, FATCA, and the multilateral convention already move account and ownership data automatically to a far wider group of countries. The sensible working assumption is that information about a Mauritius entity is reachable by your home tax authority through one channel or another, which makes accurate reporting at home the safer course than any reliance on distance.
How Expanship Can Help Your Business in Mauritius
Expanship advises foreign owners on how TIEAs and the broader exchange framework affect their Mauritius structures, from confirming which partner network applies to clarifying reporting obligations under the CRS and FATCA. The same team handles the wider set of services a foreign-owned entity needs to incorporate and stay compliant on the island.
- Company formation and entity structuring
- Registered agent and registered office services
- Tax registration and return filing with the MRA
- Ongoing compliance and statutory filing management
- Accounting and bookkeeping support
- Introductions to banking partners
To discuss your structure and obligations, contact Expanship Mauritius.
Frequently Asked Questions
Eleven TIEAs are in force as at February 2026, including the agreement with the United States signed in 2014. A further three, with Argentina, Greece, and the Isle of Man, await signature.
No. A TIEA only enables the exchange of tax information and grants no treaty benefits, while a DTAA allocates taxing rights and usually carries an Article 26-style exchange clause as one of many provisions. The island has 45 tax treaties alongside its smaller TIEA network.
Yes. The framework covers ownership information, banking records, accounting data, and material held by nominees and trustees, subject to confidentiality safeguards, so beneficial ownership and account details fall within scope.
Your home authority may still obtain information through the Convention on Mutual Administrative Assistance in Tax Matters, which the island joined in June 2015. Financial account data may also already be flowing automatically under the CRS, which has been active since 2018.
The MRA is the designated competent authority for all exchange-of-information matters and names its authorised representatives on its website. A foreign tax authority submits its request to the MRA, which gathers and verifies the data before transmitting it.
Disclosure is limited to what a specific arrangement requires and goes only to an officer authorised by the partner government. Information may be used only for tax purposes in the receiving country and may not be passed to a third state without consent.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
