Treaty signed on 7 October 2011, applied since 2013, amended by a 2021 protocol that implements the MLI
International Taxation & Mauritius
Germany ↔ Mauritius
Who taxes your pension, your rental income, your shareholdings and your estate between Germany and Mauritius.
The 2011 treaty and its 2021 protocol, read article by article in both authentic languages, and German law in force in 2026: whether you are leaving for Mauritius or buying from Germany.
What Germany keeps,
what Mauritius taxes
what Mauritius taxes
The essentials
Four rules to know before you leave or buy.
Statutory German pension: taxed in Germany only; occupational or private pension: in Mauritius, for the part you receive there
Shareholding of at least 1%: Germany taxes the unrealised gain when you leave, the Wegzugsbesteuerung (exit tax)
Inheritance: a German national remains subject to German duties five years after leaving, and an heir resident in Germany still is
01 In brief
Who taxes what between Germany and Mauritius?
It all depends on your country of residence: one table for the German resident who settles in Mauritius, another for the one who stays in Germany and invests in Mauritius.
You live in Mauritius: what Germany keeps
| Income or asset | Where it is taxed | What you need to know | Source |
|---|---|---|---|
| Statutory pension (Deutsche Rentenversicherung) | In Germany only | No basic allowance (Grundfreibetrag), unless you opt for it | Treaty, Art. 17(2); EStG, § 50 |
| Occupational pension, Riester, Rürup or private pension | In Mauritius, for the part you receive there | The part left outside Mauritius may remain taxable in Germany | Treaty, Art. 17(1); protocol, No. 3 |
| Civil servant pension | In Germany only | In Mauritius only if you are both resident and a national of Mauritius | Treaty, Art. 18(2) |
| Rental income from property located in Germany | In Germany; in Mauritius if remitted there | Taxed from the first euro; Mauritius deducts the German tax | Treaty, Arts. 6 and 23(1) |
| Capital gain on that property | In Germany | If the sale takes place within ten years of purchase | EStG, § 23 |
| Dividends from a German company | In Germany and in Mauritius | Withholding tax of 26.375%, reduced to 15% on request | Treaty, Art. 10 |
| Interest from German sources | In Mauritius only | An ordinary account is not taxable in Germany for a non-resident | Treaty, Art. 11 |
| Shareholding of at least 1% in a German company | In Germany, on departure and then on sale | Unrealised gain taxed on departure, then any later increase | AStG, § 6; treaty, Art. 13(4) |
| Salary from work performed in Mauritius | In Mauritius | Even if paid by a German employer, including a GmbH managing director | Treaty, Art. 14 |
You live in Germany and invest in Mauritius
| Income or asset | Where it is taxed | What you need to know | Source |
|---|---|---|---|
| Rental income from your Mauritian property | In Mauritius, then in Germany | Germany deducts the Mauritian tax, without exempting the rental income | Treaty, Arts. 6 and 23(2)(a) |
| Capital gain on resale | In Germany, if you sell within ten years of purchase | Mauritius does not tax it: nothing to deduct | EStG, § 23 |
| Mauritian dividends and interest | In Germany | 25% plus the solidarity surcharge; no Mauritian withholding tax | Treaty, Arts. 10 and 11; EStG, § 32d |
| Inheritance or gift of your Mauritian property | In Germany | The whole estate of a German resident is taxed; Mauritius levies no duty | ErbStG, § 2(1), No. 1 |
02 The treaty
What does the tax treaty between Germany and Mauritius contain?
Signed in Port Louis on 7 October 2011, it replaces the 1978 treaty and covers only income taxes. A 2021 protocol incorporated into it the measures of the OECD multilateral instrument (MLI) adopted by both States.
| Step | Date or content | Reference |
|---|---|---|
| Signature | 7 October 2011, in Port Louis, with a protocol of the same date | BGBl. 2012 II, p. 1050 |
| Entry into force | 7 December 2012; applied since 1 January 2013 | BGBl. 2013 II, p. 331 |
| 2021 protocol | Signed in Berlin on 29 October 2021, in force on 16 December 2022: new preamble against non-taxation, arbitration of disputes after three years; applied in Germany in 2023, in Mauritius from 1 July 2023 | BGBl. 2022 II, p. 530; BGBl. 2023 II, No. 50 |
| Multilateral instrument (MLI) | It does not amend the treaty by itself: Mauritius is not listed in the German law that implements it; its measures take effect through the 2021 protocol | BMF, status of treaties at 1 January 2026 |
| Taxes covered | Income tax (in Germany, also corporation tax, trade tax and the solidarity surcharge); no wealth tax, inheritance tax or gift tax | Treaty, Art. 2 |
| Disputes and recovery | Competent authority approached within three years, arbitration possible; assistance in the collection of taxes between the two States | Treaty, Arts. 25 and 27 |
Resident of Mauritius: a strict definition
For the treaty, an individual is a resident of Mauritius if domiciled there and subject to general Mauritian tax, as opposed to special preferential regimes (Art. 4(1)(a); protocol, No. 1). The treaty makes no reference to 183 days of presence: it requires a domicile in Mauritius.
The remittance clause
Mauritius taxes an individual’s foreign income only if it is received or used in Mauritius. In return, German tax exemption or relief applies only to the part taxed in Mauritius (protocol, No. 3): a pension or dividend left in Germany may remain taxable there.
Proof of the principal purpose
Germany grants treaty relief only to a resident of Mauritius who proves that obtaining it was neither the principal purpose nor one of the principal purposes of their activity, or of holding the asset that generates the income (Art. 22(1)).
03 Tax residence
When do you cease to be a German tax resident?
You remain liable to German tax on your worldwide income as long as you keep a home in Germany that you will retain and use, or you habitually stay there. Deregistering at the town hall (Abmeldung) does not end this on its own. If both countries consider you resident, the treaty decides.
Counting your days in Mauritius →| Criterion | Germany | Mauritius |
|---|---|---|
| Legal criterion | Home (Wohnsitz) kept in conditions showing that you will retain and use it, or habitual abode: always beyond six months of continuous presence, except for a purely private stay of up to one year (AO, §§ 8 and 9) | 183 days in the income year, or 270 days over that year and the two preceding ones; domicile in Mauritius, unless permanent residence abroad |
| Deregistration (Abmeldung) | Mandatory within two weeks of moving (BMG, § 17(2)), but with no tax effect on its own: it is merely an indication (AEAO on § 8, No. 1.2) | A residence permit does not replace the day count |
| Home kept in Germany | Kept ready to receive you and used, it maintains your Wohnsitz even if you live abroad; let long-term or put up for sale, it no longer does (AEAO on § 8, No. 6) | — |
| For the purposes of the treaty | Person liable to German tax by reason of domicile or habitual abode | Person domiciled in Mauritius and subject to general Mauritian tax |
If both countries claim you
The treaty ties you to the State where you have a permanent home; if you have one in each country, to the one with which your vital interests are closer; then to that of your habitual abode, then of your nationality; failing that, the two administrations decide together (Art. 4(2)).
Family left in Germany
If your family stays in Germany, you in principle keep a Wohnsitz there: a spouse who is not separated has theirs where the family lives, and the family home they occupy from time to time remains one (AEAO on § 8, No. 5.2).
A special Mauritian regime?
Under a regime that taxes certain income only when remitted, such as the Premium Visa for remote working (Income Tax Act, s. 73B), have it confirmed that you are subject to “general Mauritian tax” within the meaning of the protocol. Residence permits →
04 Double taxation
How does the treaty avoid being taxed twice?
By credit, on both sides: Mauritius deducts German tax from its own tax, and Germany deducts Mauritian tax from its own. Germany never exempts income that Mauritius may tax.
| You are resident in | Method | Details |
|---|---|---|
| Mauritius | Credit equal to German tax, not exceeding the Mauritian tax due on the same income | For a dividend from a German company in which you control at least 5%, the credit also takes account of the tax paid by the company (Art. 23(1)(b)) |
| Germany | Credit for Mauritian tax paid, up to the German tax attributable to Mauritian income (Art. 23(2)(a)) | Only income that the treaty reserves to Mauritius is exempt, and taken into account for the rate (Art. 23(2)(b)) |
A capped credit
Germany calculates the German tax corresponding to Mauritian income at the average rate on your total income, and credits Mauritian tax only up to that amount (EStG, § 34c(1)).
No exemption for Mauritian income
Rental income, capital gains, dividends: as a German resident, you declare them in Germany. Income that Mauritius does not tax, such as the capital gain on a villa, gives rise to no credit.
Income not covered by the treaty
It is taxable only in the State of residence, wherever it arises (Art. 21(1)).
05 On departure
The Wegzugsbesteuerung: exit taxation of shareholdings
On the day you no longer have either a Wohnsitz or a habitual abode in Germany, § 6 of the AStG treats your departure as a deemed sale of your shareholdings of at least 1%, at market value. It is not a wealth tax: property, accounts and small holdings of securities are not covered.
| Question | What the law says | Source |
|---|---|---|
| Who? | Any individual, whatever their nationality, subject to unlimited tax liability for at least seven of the twelve years preceding departure; for shares received free of charge, the donor’s years count | AStG, § 6(2) |
| Which assets? | Shares in capital companies, German or foreign, once you have held at least 1% of the capital at any time in the last five years; since 2025, fund units if you hold at least 1% or if they cost at least €500,000 | AStG, § 6(1); EStG, § 17(1); InvStG, § 19(3) |
| Which event? | The end of unlimited tax liability; the gift or transfer of the shares to a non-resident; the loss or restriction of Germany’s right to tax their sale | AStG, § 6(1), Nos. 1 to 3 |
| What tax? | Market value (gemeiner Wert) on the day of departure, less acquisition cost; 60% of that gain at the progressive scale; allowance of €9,060 pro rata, which disappears on large gains; no capital loss is taken into account | EStG, § 3 No. 40(c), and § 17; BMF, point 6.1.4 |
| When to pay? | One month after notice; on request, in seven equal interest-free instalments, as a rule against security, the following ones each 31 July | AStG, § 6(4) |
| When does everything fall due? | Unpaid instalment, sale or gift of the shares, distributions of more than a quarter of the taxed value, insolvency, missed declaration | AStG, § 6(4) |
| What to declare afterwards? | Each year before 31 July, electronically: your address and the holding of the shares; within one month, any event that makes the tax due | AStG, § 6(5) |
| And if you return? | Tax cancelled if you become subject to unlimited tax liability again within seven years (extendable by five years if the intention to return remains), without having sold or contributed the shares, without distributions of more than a quarter of their value, and if Germany regains the same right to tax | AStG, § 6(3) |
| European Union or third country? | No difference any more since 2022: the seven instalments apply to all countries, Mauritius like the others | AStG, § 6 and § 21(3) |
Does Germany keep this right despite the treaty? Yes
The deemed sale takes place when your unlimited tax liability ends, at the latest when you become a resident of Mauritius within the meaning of the treaty: Germany is still your State of residence. Administrative doctrine states this (BMF, 22 December 2023, point 6.1.7), even though Germany then keeps the right to tax the sale (point 6.1.4.1, Federal Fiscal Court, I R 30/19). Article 13(6) of the treaty confirms it for shares in a German company; for the administration, it is merely declaratory. As Mauritius does not tax these gains, there is neither double taxation nor credit.
After departure, the actual sale
For a German company, Germany may still tax the sale (Art. 13(4); EStG, § 49(1), No. 2(e)): the exit tax having been paid, only the subsequent increase is taxed (AStG, § 6(1), sentence 3). For a non-German company, the gain is taxable only in Mauritius (Art. 13(5)), which does not tax it.
Return and security
A simple declaration suffices to prove the intention to return, unless there is evidence to the contrary, and an actual return within seven years is enough (point 6.3.1.1). To grant the instalments, the Finanzamt weighs your assets, your ties with Germany and the possibilities of recovery (point 6.4.1).
A departure in two stages
Keeping a home in Germany while becoming a resident of Mauritius within the meaning of the treaty does not protect you: § 6 also applies when Germany loses its right to tax the sale of the shares (§ 6(1), No. 3), which is the case for non-German companies (Art. 13(5)).
Other effects of departure
A sole-proprietorship business asset that escapes German tax is treated as withdrawn at its value (EStG, § 4(1), sentence 3). For a Riester contract, the subsidies must be repaid if you reside outside the Union and the EEA when payments begin (EStG, § 95). The tax return for the year of departure covers the whole year.
Preparing your departure
Have your shares valued at the planned departure date, calculate the tax, prepare the security and decide the question of your return. Also gather proof of your settlement: residence permit, deed or lease, tax residence certificate from the MRA. Westimmo coordinates your settlement in Mauritius with your German adviser.
06 Extended limited tax liability
Can Germany tax more broadly after you leave?
Yes, in one specific case: a German national settled in a low-tax country who keeps essential economic interests in Germany remains taxed more broadly in the year of departure and the ten following years (AStG, § 2). According to our calculation with the 2026 scales, Mauritius meets the low-tax criterion; but the treaty prevails, which greatly reduces the scope of the rule.
| Condition | What the law provides | For a departure to Mauritius |
|---|---|---|
| Nationality and duration | German national, subject to unlimited tax liability for at least five of the ten years preceding departure | Not foreign nationals |
| Low taxation | Local tax on €77,000 of income more than one third lower than German tax, or preferential regime | About €12,617 against €21,204: 40.5% less. Criterion met, unless you prove that you pay in total at least two thirds of German tax |
| Essential economic interests | German business, shareholding of at least 1% in a German company; or non-foreign income of more than 30% of the total or €62,000; or corresponding assets of more than 30% or €154,000 | Keeping a GmbH, a let property or a large German portfolio is often enough |
| Income concerned | All income that is not “foreign” (EStG, § 34d), such as interest on an account in Germany, if its total exceeds €16,500 in the year | Rate calculated on your worldwide income; never more than if you had remained resident |
The treaty prevails
Income that the treaty reserves to Mauritius remains exempt, only the rate takes it into account, and withholding ceilings apply (BMF, point 2.0.2.1). The administration cites a contrary clause only in the treaties with Switzerland and Italy; the Germany–Mauritius treaty merely reserves domestic rules against tax avoidance (Art. 29): have its effect examined in your case.
What remains in practice
Income that the treaty leaves to Germany in any case (German rental income, German dividends up to 15%, capital gain on shares in a German company) is taxed at the rate of your worldwide income. To this are added income not received in Mauritius and that of an interposed foreign company (AStG, § 5).
Not a general rule
A foreign national who leaves Germany, or a German without essential economic interests in Germany, is not concerned. The low-taxation calculation is redone each year.
07 Property kept in Germany
What happens to a property you keep in Germany?
It remains taxed in Germany: rental income from the first euro, capital gain if you sell within ten years of purchase, property tax every year, and inheritance duties whatever your country of residence at death.
Rental income
Taxable in Germany (Art. 6; EStG, § 49(1), No. 6), by a return to the Finanzamt of the place of the property, related expenses deducted. As a non-resident, you do not have the Grundfreibetrag of €12,348 (EStG, § 50(1)), except by option if at least 90% of your income is taxable in Germany or if your other income does not exceed €6,174, the amount applied for Mauritius in 2026, on certification by the Mauritian administration (EStG, § 1(3)). Mauritius taxes it only when remitted, less the German tax.
Capital gain
Taxable if the property is sold within ten years of purchase (EStG, § 23; treaty, Art. 13(1)), unless it has been used exclusively as your own home since purchase, or in the year of sale and the two preceding ones. For a former main residence sold after departure, the calendar decides: have it checked before signing.
Property tax and inheritance
The Grundsteuer remains due every year by the owner, resident or not (GrStG, § 10). On your death, German real estate is always taxable in Germany (ErbStG, § 2(1), No. 3; BewG, § 121).
08 Investing in Mauritius
You buy in Mauritius from Germany: who taxes what?
Mauritius taxes first: registration duty on purchase, rental income at the scale, no capital gains tax. Germany then taxes, without exemption: rental income, deducting Mauritian tax, and the gain on a resale within ten years.
Tax on rental income in Mauritius →In Mauritius
5% registration duty and notary fees on purchase; a property of at least USD 375,000 bought under a scheme grants a residence permit. Rental income taxed at the scale, without the residents’ allowances; a tenant that is not an individual withholds 10% at source. Rs 2,000,000 of net rent, about €37,110, gives Rs 250,000 of tax, i.e. 12.5%. Purchase costs →
In Germany
The rent, recalculated under German rules, depreciation included, is added to your income; Mauritian tax is credited up to the corresponding German tax (EStG, § 34c): you pay, as a rule, the higher of the two. A loss can be offset only against income of the same kind from the same country (EStG, § 2a).
Resale and transfer
Mauritius does not tax an individual’s capital gain; the seller pays 5% transfer tax. Germany taxes it if you sell within ten years of purchase, unless used exclusively as your own home, to be confirmed. The villa forms part of your estate and of your German gifts. Reselling →
09 Salaries, activity, companies
Do you work or run a company between the two countries?
A salary is taxed where the work is done, including that of a GmbH managing director. Keeping your GmbH when you leave is possible, but it goes through exit taxation; and a Mauritian company held from Germany has its own obligations.
Self-employed or Premium Visa →Employee and remote working
The salary is taxable where the work is performed, except for a stay of no more than 183 days in twelve months for an employer of the other State with no establishment on site (Art. 14). Working remotely from Mauritius for a German employer means working in Mauritius (Income Tax Act, s. 74): check that your residence permit allows it.
The managing director and their GmbH
German law covers the remuneration of the managing director of a company managed from Germany (EStG, § 49(1), No. 4(c)), but the treaty treats it as a salary: work done in Mauritius falls to Mauritius (Art. 14). Only members of a supervisory or administrative board remain taxable in Germany (Art. 15). Managing the GmbH from Mauritius may create a permanent establishment there (Art. 5) and, in Germany, taxation of the unrealised gains on the assets attributed to it (KStG, § 12): to be examined before you leave.
A Mauritian company
15% corporate tax and no withholding on its dividends. As a German resident, you declare to the Finanzamt a shareholding of at least 10% or costing more than €150,000, and any controlling influence over it (AO, § 138(2)); if it receives passive income taxed at less than 15%, that income may be attributed to you (AStG, §§ 7 and 8). For its German income, it must be a “qualifying company” (Art. 22(2)). Buying through a company →
10 Investments
Dividends, interest and capital gains: who taxes what?
There is no single German rate: 25% plus the solidarity surcharge on dividends, interest and small capital gains of a resident; the progressive scale on 60% of gains on shareholdings of at least 1%; a withholding reduced to 15% on German dividends of a resident of Mauritius.
| Income | You reside in Mauritius | You reside in Germany |
|---|---|---|
| Dividends from a German company | Withholding of 25% plus 5.5% solidarity surcharge, i.e. 26.375%, refunded above 15% on request | 25% plus the solidarity surcharge, withheld by the bank |
| Interest from a German bank | Not taxable in Germany; Mauritius only | 25% plus the solidarity surcharge, after the €1,000 allowance (€2,000 for a couple) |
| Mauritian dividends and interest | Outside the scope of German tax | 25% plus the solidarity surcharge, to be declared |
| Capital gain, at least 1% of a German company | Germany (Art. 13(4)): scale on 60% of the gain | Scale on 60% of the gain |
| Capital gain, less than 1% of a German company | Not taxed in Germany; Mauritius does not tax it | 25% plus the solidarity surcharge |
| Capital gain, non-German company | Mauritius only (Art. 13(5)), which does not tax it | Scale on 60% or 25%, depending on the shareholding |
Recovering the German withholding tax
Online application to the Bundeszentralamt für Steuern (BZSt), with the bank’s certificate and a tax residence certificate from the MRA, within four years of the year of payment (EStG, § 50c(3)). The reduction applies only to the part of the dividends received in Mauritius (protocol, No. 3), which taxes it less the German tax.
Your German accounts
You may keep them: ordinary bank interest is not German income for a non-resident (EStG, § 49(1), No. 5). Tell your bank about your departure.
The 1% threshold
It is assessed over the five years preceding the sale, directly or indirectly (EStG, § 17(1)): a shareholding reduced below 1% shortly before the sale remains covered.
11 Pensions and retirement
Where is your German pension taxed?
There is no single “German pension”: the statutory pension is taxed only in Germany; occupational and private pensions are taxed in Mauritius, for the part you receive there; public pensions remain German, except for a resident who is a Mauritian national.
| Pension | Article | Where it is taxed | German treatment |
|---|---|---|---|
| Statutory pension: old age, disability, survivor’s (Deutsche Rentenversicherung) | Art. 17(2): public social security scheme | Germany only | Taxable share depends on the year of retirement, 84% for 2026; Finanzamt Neubrandenburg |
| Civil servant pension, pension from a public body | Art. 18(2) | Germany only; Mauritius only for a resident who is a Mauritian national | Taxed as a salary, withheld by the former public employer |
| Occupational pension paid by the employer or a support fund | Art. 17(1) | Mauritius, for the part received in Mauritius | Withheld by the former employer; exemption to be requested from the Finanzamt for the remitted part |
| Occupational pension from a Pensionskasse, Pensionsfonds or direct insurance | Art. 17(1) | Mauritius, for the part received in Mauritius | Taxable as German income for the part not remitted (EStG, § 49(1), No. 10) |
| Riester pension | Art. 17(1) | Mauritius, for the part received in Mauritius | Subsidies to be repaid if you reside outside the Union and the EEA when payments begin (EStG, § 95) |
| Rürup pension, private life annuity | Art. 17(1) | Mauritius, for the part received in Mauritius | Taxable as German income for the part not remitted (EStG, § 49(1), No. 7) |
| Professional scheme (Versorgungswerk), supplementary public-service pension | To be characterised | Depending on the characterisation | Have the Finanzamt rule on it before you leave |
| Lump-sum payment | Art. 17(1), to be confirmed depending on the contract | To be confirmed | Depending on the nature of the contract |
Why “for the part received in Mauritius”
Mauritius taxes a foreign pension only if it is received or used in Mauritius (Income Tax Act, s. 5(3)); Germany therefore gives up taxing only that part (protocol, No. 3). Have your pensions paid into an account in Mauritius, or transfer them, and keep the statements.
The statutory pension
Taxable share set by the year of first payment: 83% for 2024, 84% for 2026, 100% in 2058 (EStG, § 22). As a non-resident, you do not have the Grundfreibetrag, except by option if at least 90% of your income is taxable in Germany or if your other income does not exceed €6,174 in 2026 (EStG, § 1(3), and § 50).
On the Mauritian side
A pension received in Mauritius is taxed there at the scale, with a credit for foreign tax if it is taxable there. The Rs 3,000,000 exemption on a retirement lump sum applies to an approved fund: it is not automatic for a German contract. A lump sum does not become taxable merely because it is transferred.
12 Inheritance and gifts
Can Germany still tax your estate after you leave?
Yes, in three cases: during the five years following the departure of a German national; at any time, for what is received by an heir or donee resident in Germany; and always for property located in Germany. Mauritius levies neither inheritance duties nor gift duties, and no treaty governs the question.
When Germany taxes
| Situation at death or gift | Liability | Property taxed |
|---|---|---|
| Deceased or donor with a Wohnsitz or habitual abode in Germany | Unlimited | The whole estate, Mauritian villa included |
| Deceased or donor who is a German national, abroad for no more than five years, with no Wohnsitz in Germany | Unlimited (ErbStG, § 2(1), No. 1(b)) | The whole estate |
| Heir or donee with a Wohnsitz or habitual abode in Germany | Unlimited, whoever the deceased | Everything they receive, wherever the property is |
| Beyond five years, within ten years of the year of departure, if the deceased fell under § 2 of the AStG | Extended limited (AStG, § 4) | German property in the broad sense, accounts and securities included, except for foreign tax of at least 30% of German tax |
| All other cases | Limited (ErbStG, § 2(1), No. 3) | German real estate and business assets, shareholdings of at least 10% in a German company; not accounts |
Allowances and rates
| Beneficiary | Class | Allowance | Rate |
|---|---|---|---|
| Spouse, registered partner | I | €500,000, plus on death €256,000, reduced by untaxed survivor’s pensions | 7% to 30% |
| Children | I | €400,000 | 7% to 30% |
| Grandchildren | I | €200,000 | 7% to 30% |
| Parents and grandparents, on death | I | €100,000 | 7% to 30% |
| Siblings, nieces and nephews, parents-in-law, sons- and daughters-in-law, ex-spouse | II | €20,000 | 15% to 43% |
| Other persons | III | €20,000 | 30% or 50% |
Heirs who stayed in Germany
Children resident in Germany are taxed there on everything they receive from you, even twenty years after your departure, Mauritian villa included, after their allowance of €400,000 each.
Five years, for Germans only
The rule follows the German nationality of the deceased or donor. It assumes that they no longer have any Wohnsitz in Germany: keeping one keeps them resident for these duties. Nothing to credit on the German side: Mauritius levies no duty (ErbStG, § 21).
Giving your GmbH shares
Giving or bequeathing shares of at least 1% to a non-resident also triggers exit taxation (AStG, § 6(1), No. 2), in addition to gift duties. Prepare the transfer with a notary in Mauritius and an adviser in Germany.
13 Assets and transfers
Wealth tax, money transfers: what should you know?
Neither Germany nor Mauritius levies a wealth tax. But assets remain taxed in other ways, and large transfers must be reported in Germany.
Open an account in Mauritius →No wealth tax
The Federal Constitutional Court allowed it to apply only until 31 December 1996 (decision of 22 June 1995); with no new law, it has not been levied since 1997. Mauritius levies none.
Assets taxed in other ways
Property tax on each property located in Germany, exit taxation of shareholdings of at least 1%, and inheritance duties still apply.
Transferring your money
No exchange controls in Mauritius since July 1994, according to the Bank of Mauritius; the bank and the notary check the origin of the funds. A German resident reports to the Bundesbank payments of more than €50,000 to a non-resident, such as the price of a villa (AWV, § 67): a statistical declaration, not a tax.
14 Declarations
Which declarations, and what do the administrations exchange?
In Germany: deregistration, the return for the year of departure, then those for your German income. In Mauritius: a tax number and the return by 15 October. Between the two, your account data circulate automatically.
Declaring on arrival in Mauritius →| When | In Germany | In Mauritius |
|---|---|---|
| On departure | Deregistration within two weeks; return for the whole year, exit gain included; possible request for instalments | Tax number (TAN) from the MRA; income year from 1 July to 30 June |
| Each year thereafter | German income: rental income to the Finanzamt of the place of the property, pensions to the Finanzamt Neubrandenburg; notification before 31 July in case of instalments | Return and payment by 15 October at the latest |
| German withholding tax to recover | Online application to the BZSt within four years | Tax residence certificate from the MRA, issued within seven days if your returns are up to date |
| German resident investing in Mauritius | Mauritian income and Mauritian tax paid; shareholding in a Mauritian company; payments of more than €50,000 to the Bundesbank | Declaration of Mauritian rental income |
Proof of your residence
To benefit from the treaty, prepare the MRA tax residence certificate, the deed or lease, the residence permit and proof of your domicile in Mauritius.
On request and automatically
On request, any information foreseeably relevant, bank secrecy included (Art. 26). Automatically, financial account data: Mauritius is on the German exchange list for 2026 (BMF, 8 June 2026), and Mauritian banks report non-residents’ accounts each year.
What this changes
The Mauritian account of a German resident is known to the German administration: its income must appear in the return. A tax debt may be recovered in the other State (Art. 27).
15 Practical cases
Four common situations
The rules above applied to four profiles we often meet. Amounts calculated with the 2026 scales, as examples.
| Situation | What applies |
|---|---|
| A couple from Munich settle in Tamarin and keep their flat | Kept ready and used during their stays, the flat maintains their Wohnsitz: the treaty decides, in favour of Mauritius if their life is centred there. Let long-term, it no longer maintains it; its rental income remains taxed in Germany from the first euro, and Mauritius taxes it only when remitted, German tax deducted. Sold less than ten years after purchase, it escapes tax only if the occupancy calendar allows. |
| An entrepreneur leaves with her GmbH | Sole shareholder for twenty years; shares subscribed at €25,000, value €2,000,000 at departure. Exit gain €1,975,000, of which 60% taxable, i.e. €1,185,000: about €513,779 of income tax, plus €28,257 of solidarity surcharge, the income tax payable in seven instalments of about €73,397, as a rule against security. If she returned within seven years, the tax would fall away; if she sold later, the exit tax having been paid, she would be taxed in Germany on the increase above €2,000,000. |
| A retiree from Hamburg receives three pensions | His statutory pension of €21,600 a year, begun in 2024, remains taxed in Germany only, on 83%, i.e. €17,928. His Pensionskasse pension falls to Mauritius for the part he has transferred there. His civil servant pension from a Land remains taxed in Germany. His Riester contract: the subsidies must be repaid, because he lives outside the Union when payments begin. |
| A couple from Düsseldorf buy a villa in Grand Baie without leaving Germany | Rs 2,000,000 of net rent: Rs 250,000 of tax in Mauritius; in Germany, the rent is added to their income and Mauritian tax is credited. Resold after six years, the gain is taxed in Germany; after eleven years, it is not. The price paid is reported to the Bundesbank; on their death, the villa forms part of their German estate. |
16 Related guides
Going further
The main guide and the pages detailing each topic. In German, our detailed files: Erbschaftsteuer, Rückkehr nach Deutschland, Checkliste Auswanderung, Sozialversicherung, Renditeimmobilie oder Immobilienfonds.
International Taxation & MauritiusThe main guide, country by country→
Purchase costsThe real cost of a purchase, line by line→
Tax on rental incomeThe scale applied, worked examples→
Selling from abroadTransfer tax and procedures→
Visas, permits and residenceAll the routes to live in Mauritius→
Living in MauritiusPreparing your departure and your first year→17 Sources & methodology
Reliable, up-to-date information
Each rule comes from the treaty, a legal text or an official publication of the German or Mauritian authorities, read on 29 September 2026.
BMFFederal Ministry of FinanceBGBl.Federal Law GazetteMRAMauritius Revenue AuthorityTreatyGermany–Mauritius, 2011
- Germany–Mauritius treaty of 7 October 2011 and protocol of the same date (BGBl. 2012 II, p. 1050; MRA, Government Notice No. 210 of 2012); entry into force: BGBl. 2013 II, p. 331
- Protocol of 29 October 2021, implementing the MLI (BGBl. 2022 II, p. 530; MRA, Government Notice No. 301 of 2021); entry into force on 16 December 2022: BGBl. 2023 II, No. 50
- Federal Ministry of Finance (BMF): status of treaties at 1 January 2026; principles for applying the AStG of 22 December 2023; remittance clauses (20 June 2013); country groups (2 December 2025); CRS exchange list 2026 (8 June 2026); implementing instruction AEAO on § 8 (2025)
- Texts in force: AO, §§ 8, 9 and 138; EStG, §§ 1, 2a, 3, 4, 17, 20, 22, 23, 32a, 32d, 34c, 43a, 49, 50, 50c and 95; AStG, §§ 2, 4, 5, 6, 7 and 8; InvStG, § 19; ErbStG, §§ 2, 15, 16, 17, 19 and 21; BewG, § 121; KStG, § 12; GrStG, § 10; AWV, § 67; BMG, § 17
- Federal Constitutional Court, decision of 22 June 1995 (wealth tax); Finanzamt Neubrandenburg (retirees abroad); BZSt (refund of withholding tax on investment income)
- Mauritius: Finance Act 2026, Section 7(v); Income Tax Act, ss. 5(3), 73, 73B and 74; MRA, list of treaties in force (29 September 2026); Bank of Mauritius: exchange controls abolished in July 1994; indicative rate of 21 September 2026: €1 = Rs 53.8912
Texts read and verified on 29 September 2026. This guide sets out the rules of both countries; it does not replace the advice of a tax adviser, in Germany and in Mauritius, on your situation.
18 Frequently asked questions
Your questions on taxation between Germany and Mauritius
Short answers, backed by official texts.
Frequently asked questions: Germany ↔ Mauritius
Yes. Signed in Port Louis on 7 October 2011, it has applied since 1 January 2013 to income taxes. A 2021 protocol, in force since 16 December 2022, incorporated the MLI measures into it. It covers neither inheritance nor gifts.
No. Deregistration is mandatory, but has no tax effect on its own. You remain liable as long as you keep a home in Germany that you will retain and use, or you habitually stay there.
Yes, but kept ready to receive you and used, it maintains your Wohnsitz: the treaty then decides your residence. Let long-term, it no longer maintains it; its rental income remains taxed in Germany from the first euro.
It is the exit taxation under § 6 of the AStG: your departure is treated as a deemed sale of your shareholdings of at least 1%, at market value. The unrealised gain is taxed on 60% at the scale, payable in seven instalments on request, and the tax is cancelled if you return within seven years.
No. It covers shares in capital companies, German or foreign, from 1% of the capital held at any time in the last five years, if you have been liable for at least seven years out of twelve; since 2025, also certain fund units. Small holdings of securities, property and accounts are not covered.
Yes. The deemed sale takes place when your unlimited tax liability ends, when Germany is still your State of residence: the administration holds that the treaty does not prevent it, and Article 13(6) confirms it for German companies. For these, Germany may also tax the later actual sale.
It depends on its nature. The statutory pension is taxable only in Germany; so is a civil servant pension, except for a resident who is a Mauritian national. An occupational pension, a Riester, Rürup or private pension is taxable only in Mauritius, for the part you receive there.
Mauritius taxes a foreign pension only if it is received or used in Mauritius; Germany therefore gives up taxing only that part. Have your pensions paid into an account in Mauritius, or transfer them, and keep the statements.
Yes, but departure triggers exit taxation if you hold at least 1% of the capital. Afterwards, Germany may tax the sale of those shares, its dividends suffer a withholding reduced to 15% on request, and your managing director’s salary, for work done in Mauritius, falls to Mauritius.
As a German resident, you declare it in Germany and Mauritian tax is credited up to the corresponding German tax: the treaty does not exempt it. A resale within ten years of purchase is taxed in Germany.
Yes, in three cases: during the five years following the departure of a German national; at any time, for what is received by an heir resident in Germany; and always for property located in Germany. Mauritius levies no inheritance duty.
As a German resident, yes: its interest and dividends are declared in Germany, at 25% plus the solidarity surcharge. The German administration receives the data under the CRS: Mauritius is on the German exchange list for 2026.