Treaty signed in Port Louis on 9 March 1990, in force since 28 April 1995, amended by the 2010 protocol; the OECD multilateral instrument (MLI), signed by Italy in 2017, has not been ratified by it: it does not amend the treaty
International Taxation & Mauritius
Italy ↔ Mauritius
Who taxes your rent, your capital gains, your pensions and your estate between Italy and Mauritius.
The 1990 treaty and its 2010 protocol, read in their current text, and Italian law for 2026: residence, the list of privileged-tax States, IVIE, IVAFE, the RW section. For leaving Italy as well as for investing in Mauritius while remaining a resident.
For Italy, moving to Mauritius
has to be proven, with supporting documents
has to be proven, with supporting documents
The essentials
Four rules to know before leaving or buying.
Mauritius appears on the Italian list in the decree of 4 May 1999: an Italian citizen who settles there remains presumed to be an Italian tax resident until proven otherwise, and investments held there by an Italian resident bear IVAFE at 4‰ instead of 2‰
Italian residence: civil residence, domicile, physical presence or registration in the population register for the greater part of the year, fractions of a day included; a single criterion is enough, and the year cannot be split
Pension from private employment: taxable in Mauritius only, provided it is subject to tax there; civil service pension: in Italy only, unless you are Mauritian and resident in Mauritius
01 In brief
Who taxes what between Italy and Mauritius?
The 1990 treaty allocates income: property is taxed where it is located, private-employment pensions and capital gains on securities where you reside, Italian dividends at 15% at most. It covers neither IVIE, nor IVAFE, nor estates, and it only applies if you prove your residence in Mauritius.
Profile A — you have become a resident of Mauritius
| Income or asset | Where it is taxed | What you need to know | Source |
|---|---|---|---|
| Rent from a property in Italy | In Italy; in Mauritius if received there, with credit | IRPEF at the progressive scale on rent reduced by 5%, or cedolare secca at 21% by option | Treaty, art. 6 and 23; TUIR, art. 23 and 37 |
| Sale of an Italian property | In Italy | Taxable if the property was bought or built five years ago or less | Treaty, art. 13, 1; TUIR, art. 67 |
| Dividends from an Italian company | In Italy, 15% at most; in Mauritius if received there, with credit | 26% under domestic law, reduced to 15% by the treaty | Treaty, art. 10 and 28 |
| Interest from an Italian bank account | In Mauritius if received there | Italian law does not treat it as Italian-source income for a non-resident | TUIR, art. 23, 1, b |
| Capital gains on shares and units | In Mauritius only | Mauritius does not tax an individual's capital gain | Treaty, art. 13, 3 |
| Pension from private employment | In Mauritius only, if it is subject to tax there | Otherwise Italy may tax it; request to INPS | Treaty, art. 18 |
| Civil service pension | In Italy only | Unless you hold Mauritian nationality and reside in Mauritius | Treaty, art. 19, 2 |
| Estate | According to the deceased's residence | Deceased not resident in Italy: only their assets located in Italy are taxed there | Consolidated Inheritance Act, art. 2; outside the treaty |
| Wealth | — | Neither IVIE nor IVAFE for a person not resident in Italy; Mauritius has no general wealth tax | DL 201/2011, art. 19 |
Profile B — you remain an Italian resident and invest in Mauritius
| Income or asset | Where it is taxed | What you need to know | Source |
|---|---|---|---|
| Rent from a villa in Mauritius | In Mauritius, then in Italy with credit | Mauritian scale; Italy takes the net income as assessed in Mauritius | Treaty, art. 6 and 23; TUIR, art. 70 and 165 |
| Sale of the villa | In Mauritius, which does not tax capital gains; in Italy | Taxable in Italy if the resale takes place within five years of purchase | Treaty, art. 13, 1; TUIR, art. 67 |
| The villa itself | In Italy: IVIE | 1.06% a year of the purchase price; to be declared in the RW section | DL 201/2011, art. 19; DL 167/1990, art. 4 |
| Mauritian bank account | In Italy: IVAFE | €34.20 per account if the average balance exceeds €5,000; RW section above €15,000 | DL 201/2011, art. 19 |
| Securities and investments held in Mauritius | In Italy: IVAFE | 4‰ a year, instead of 2‰: Mauritius is on the 1999 list | DL 201/2011, art. 19, c. 20-bis |
| Dividends from a Mauritian company | In Italy | No withholding in Mauritius; 26%, or the full scale if the company falls under a privileged regime | TUIR, art. 18, 47 and 47-bis |
| Estate | In Italy, on all assets | Mauritian villa included if the deceased resided in Italy | Consolidated Inheritance Act, art. 2 |
02 The treaty
Is there a tax treaty between Italy and Mauritius?
Yes. Signed in Port Louis on 9 March 1990, it has been in force since 28 April 1995 and has been amended once, by the protocol of 9 December 2010. The OECD multilateral instrument (MLI) does not amend it: Italy signed it in 2017 without ratifying it.
| Step | Date or content | Reference |
|---|---|---|
| Signature | 9 March 1990, in Port Louis | List of the Italian Ministry of Finance |
| Entry into force | 28 April 1995; Italian law no. 712 of 14 December 1994 | Ministry list; MRA |
| Effect | Retroactive: 1 January 1987 in Italy, 1 July 1987 in Mauritius | Art. 29 |
| 2010 protocol | Signed on 9 December 2010, in force on 19 November 2012 (law no. 166 of 31 August 2012): taxes covered, elimination of double taxation, exchange of information | Art. 2, 23 and 26 |
| Multilateral instrument (MLI) | Signed by Italy on 7 June 2017, with no instrument of ratification deposited at 15 September 2026; in force for Mauritius since 1 February 2020. It therefore changes nothing to date: the MRA publishes no synthesised text for Italy | OECD, signatories and parties; MRA |
| Taxes covered | Italy: IRPEF, IRES and IRAP; Mauritius: income tax | Art. 2 |
| Exchange of information | Information "foreseeably relevant", for taxes of every kind; bank secrecy cannot be invoked | Art. 26 |
| Mutual agreement procedure | To be initiated within two years; no arbitration; it does not replace domestic remedies, which should be pursued as a protective measure | Art. 25; protocol |
What the treaty does not have
No article on estates or on wealth: IVIE and IVAFE remain outside the treaty. No assistance in the collection of taxes. No clause on real-estate-rich companies or on former residents, no rule splitting the year of departure.
The Italian tax credit has a limit
Italy credits Mauritian tax up to the amount of Italian tax due on the same income. No credit is given if that income bears a substitute tax or a final withholding tax in Italy, even at the taxpayer's option (art. 23, rewritten in 2010).
A new consolidated text in 2027
The Italian consolidated income tax act (TUIR) applies until 31 December 2026. Legislative Decree no. 117 of 19 June 2026 replaces it on 1 January 2027: the article numbers cited here are those of 2026.
03 Italian list
Is Mauritius on an Italian blacklist?
Yes, for the residence of individuals and for the monitoring of assets: Mauritius appears on the list in the ministerial decree of 4 May 1999 of privileged-tax States. Three consequences follow. Dividends and controlled companies, for their part, follow another criterion, calculated company by company.
| Rule | What it provides | Who is concerned | Source |
|---|---|---|---|
| Presumption of residence | An Italian citizen removed from the population register and settled in a State on the list is deemed to be an Italian resident, unless proven otherwise | Italian citizens; not foreigners leaving Italy | TUIR, art. 2, c. 2-bis |
| IVAFE doubled | 4‰ a year, instead of 2‰, on the value of financial products held in a State on the list, since 2024 | Italian residents | DL 201/2011, art. 19, c. 20-bis |
| Undeclared assets | An asset held in a State on the list and omitted from the RW section is presumed to consist of income withheld from taxation, unless proven otherwise; penalties doubled, audit periods doubled | Italian residents | DL 78/2009, art. 12 |
Where the information comes from
Mauritius ("Maurizio") appears in the copy of the decree published by the Agenzia delle Entrate. According to its circular 20/E of 4 November 2024, the latest update, in 2023, removed only Switzerland, with effect from 1 January 2024.
Proof to the contrary
The administration requires full demonstration that all significant ties with Italy have been severed and, in parallel, proof of a genuine and lasting settlement in the host country (circular 20/E, which restates circular 140 of 1999). It is a file to be built, not a formality.
A different criterion for companies
For dividends and controlled foreign companies, Italy does not use this list: it compares the level of taxation, company by company (TUIR, art. 47-bis and 167). Sections 11 and 14.
04 Tax residence
When do you cease to be an Italian tax resident?
When, for the greater part of the calendar year, you no longer have in Italy a civil residence, a domicile or a physical presence, and are no longer registered in the population register. Each criterion is enough on its own. Since 2024, domicile is the place of your personal and family relations.
Counting days in Mauritius →| Criterion | Italy | Mauritius |
|---|---|---|
| Duration | The greater part of the tax period: 183 days, 184 in a leap year | 183 days in the income year, or 270 days over that year and the two preceding ones |
| Physical presence | Enough on its own; fractions of a day count | Counted in days of presence |
| Domicile | The place where your personal and family relations mainly develop | Domicile in Mauritius, unless permanent residence abroad |
| Civil residence | The habitual dwelling | — |
| Population register | Registration for the greater part of the year: a presumption, which you can rebut since 2024 | — |
| Italian citizens who have left for Mauritius | Presumed to be Italian residents, unless proven otherwise | — |
| Remote working | Working from Italy for a foreign employer counts as presence in Italy | — |
| Period | Calendar year, with no split year: you are resident or not for the whole year | Income year from 1 July to 30 June |
A single criterion is enough
The criteria are alternative. Spending fewer than 183 days in Italy is therefore not enough: if your spouse and children live there for the greater part of the year, your domicile remains there, whatever the number of your days.
AIRE is not enough
Registration in the register of Italians resident abroad (AIRE) removes you from the register of the resident population: it rules out one presumption, not the other criteria. The administration cites the case of a person registered with AIRE who keeps a home at their disposal in Italy and returns every weekend: these are indications of an Italian domicile.
Resident in both countries
Italy reasons by calendar year, Mauritius from 1 July to 30 June: you can be resident in both countries over the same period. The treaty then decides (next section).
05 Dual residence
What happens if both countries regard you as resident?
The treaty decides, and it prevails over Italian domestic law: permanent home, then centre of vital interests, habitual abode, nationality, and finally agreement between the administrations. But it is for you to provide proof of each criterion.
| Rank | Criterion | When it decides |
|---|---|---|
| 1 | Permanent home | You have one in only one of the two countries |
| 2 | Centre of vital interests | You have a home in both countries: the one where your personal and economic ties are closest prevails |
| 3 | Habitual abode | The centre of interests cannot be determined, or you have a permanent home in neither country |
| 4 | Nationality | You habitually stay in both countries, or in neither |
| 5 | Mutual agreement | You hold both nationalities, or neither: the administrations decide |
The treaty prevails
Italian law itself provides for this: treaties apply as a derogation from domestic law, which applies only if it is more favourable (TUIR, art. 169; DPR 600/1973, art. 75). Circular 20/E of 2024 recalls this for residence: in the event of dual residence, the treaty's tie-breaker rule prevails.
The Mauritian residence certificate
The MRA issues a tax residence certificate. It is the document requested by INPS, banks and the Italian administration to apply the treaty. It proves your residence in Mauritius, not the end of your ties with Italy.
Your residence in Mauritius
Buying or renting your residence, obtaining the accompanying permit: Westimmo organises these steps with you, with supporting documents. Residence permits →
06 Leaving Italy
How do you leave Italy for Mauritius without remaining a resident?
By choosing the date and emptying each criterion. Italy does not split the year: from 183 days of presence, domicile or registration in the calendar year, you remain an Italian resident for the whole year, taxed on your worldwide income. The treaty with Mauritius provides no split of the year.
Preparing your move →| Step | What to do | Why |
|---|---|---|
| Population register | Have yourself removed; for an Italian citizen, by registering with AIRE | Registration for the greater part of the year gives rise to a presumption of residence |
| Housing | Sell, let on a lasting basis or stop occupying the Italian home | A home kept available is an indication of domicile, and a permanent home within the meaning of the treaty |
| Family | Settle your spouse and children in Mauritius | Domicile is the place of personal and family relations |
| Days | Stay under 183 days of presence in Italy in the calendar year, fractions of a day included | Physical presence is enough on its own |
| Mauritian evidence | Residence permit, lease or title deed, tax number, MRA residence certificate, bills, schooling | An Italian citizen must rebut the presumption of residence |
| Italian return | File in Italy according to your status for the year: resident, on all your income; non-resident, on your Italian-source income only | The year is not split |
The year of departure
Departure in March: fewer than 183 days in Italy, you may be a non-resident for the whole year if the other criteria are emptied. Departure in September: you are an Italian resident for the whole year, autumn Mauritian income included; article 4, 2 of the treaty remains, to be analysed before leaving.
You are not an Italian citizen
The presumption linked to the 1999 list concerns only Italian citizens. A French national who leaves Italy for Mauritius falls under the ordinary criteria.
What AIRE is
The register of Italians resident abroad receives the records withdrawn from the register of the resident population following a permanent transfer abroad; a stay of twelve months or less does not give rise to it (law 470/1988, art. 1, c. 2 and 8).
07 Departure and exit tax
Does leaving Italy trigger an exit tax?
The Italian exit taxation text targets those who carry on a commercial business and transfer their tax residence. An individual who holds their securities privately is outside its scope. That does not mean a departure is neutral: have your situation analysed before leaving.
| Situation | What the text read provides | Source |
|---|---|---|
| You carry on a commercial business and transfer your tax residence to Mauritius | Taxation, on departure, of the business's unrealised gains | TUIR, art. 166 |
| Staggered payment | Five annual instalments, for a transfer to a State of the European Union or the European Economic Area only: not to Mauritius | TUIR, art. 166, c. 9 |
| You hold shares or units privately | Outside the scope of article 166, which targets the carrying on of a commercial business | TUIR, art. 166 |
| You sell your securities after departure | Italian law: the capital gain on a holding in an Italian company is Italian-source income, except for non-qualifying listed securities. Treaty: taxable in the State of residence only | TUIR, art. 23, 1, f; treaty, art. 13, 3 |
| Your company | Managed from Italy, it remains resident there: section 14 | TUIR, art. 73 |
What we do not claim
We do not write that Italy has "no exit tax" for individuals: we write that article 166, read in its version in force, targets the commercial business. Have it confirmed by Italian counsel before departure.
The capital gain after departure
The treaty reserves capital gains on shares and units to the State of residence (art. 13, 3), and Mauritius does not tax an individual's capital gain. The Italian exemption therefore assumes that you are recognised as a resident of Mauritius on the day of the sale, supported by a certificate.
The real risk: remaining a resident
For an Italian citizen settled in Mauritius, the first risk is not an exit tax but the presumption of residence. If it is not rebutted, Italy taxes all your income, capital gains included.
08 A property kept in Italy
What happens to the apartment you keep in Italy?
It remains taxed in Italy: the treaty leaves property to the country where it is located. Rent at the IRPEF scale or at the cedolare secca of 21%, IMU each year to the municipality, capital gain taxable if you resell within five years of purchase.
| Subject | Italian rule | Example | Source |
|---|---|---|---|
| Rent, ordinary regime | IRPEF at the 2026 scale: 23% up to €28,000, 33% up to €50,000, 43% above, on rent reduced by 5% | Rent of €14,400: base of €13,680, tax of €3,146, excluding additional regional and municipal taxes | TUIR, art. 11, 23, 24 and 37 |
| Rent, cedolare secca | By option, flat tax of 21% of the rent (10% for certain agreed-rent leases); reserved for individuals who let a dwelling outside any business activity | Rent of €14,400: €3,024 | D.Lgs. 23/2011, art. 3 |
| Short-term lets | Up to 30 days: 26%, or 21% for a single dwelling designated in the return | — | DL 50/2017, art. 4 |
| IMU | Annual municipal tax on the property's cadastral value: cadastral income revalued by 5%, multiplied by 160 for a dwelling. Base rate of 0.86% outside the main residence, which the municipality may raise to 1.06% (up to 0.08 points more, in place of the TASI surcharge) or reduce to zero | Depending on the municipality | Law 160/2019, art. 1, c. 745, 754 and 755 |
| Sale | Capital gain taxable if the property was bought or built five years ago or less; a property received by inheritance is not covered. At the scale, or 26% by option before the notary | Purchase €250,000, resale €320,000: €18,200 by option, €22,300 at the scale | TUIR, art. 67; law 266/2005, art. 1, c. 496 |
On the treaty side
Article 6 leaves rent to Italy, article 13, 1 the capital gain. Mauritius taxes Italian rent only if it is received there, and then deducts the Italian tax (Income Tax Act, s. 5(3) and 77). The repatriated sale price is capital.
Cedolare secca and non-residents
The circular of the Agenzia delle Entrate commenting on this regime (26/E of 2011) makes no distinction according to the lessor's residence. Have the option validated by your adviser.
Additional taxes to IRPEF
IRPEF is accompanied by a regional surcharge, at the base rate of 1.23% which each region may increase by its law within the limit set by the State (D.Lgs. 446/1997, art. 50), and by a municipal surcharge, which the municipality may vary by no more than 0.8 points (D.Lgs. 360/1998, art. 1). The first is calculated at the rate of the region where the taxpayer has their residence; the second is due to the municipality where they have their tax domicile on 1 January. The examples on this page do not include them: their rate depends on the region and the municipality.
09 Investing in Mauritius
As an Italian resident, you buy in Mauritius: who taxes what?
Mauritius taxes the villa's rent, and so does Italy, deducting the Mauritian tax. Two obligations specific to Italy are added: IVIE, 1.06% a year of the purchase price, and declaration of the property in the RW section. A resale within five years is taxable in Italy.
Investing in Mauritius →| Subject | In Mauritius | In Italy | Source |
|---|---|---|---|
| Purchase | Registration duty of 5%: €30,000; residence permit possible depending on the programme | Nothing on purchase; the property enters the RW section | DL 167/1990, art. 4 |
| Rent | Mauritian scale; 10% withholding if the tenant is not an individual | IRPEF on net income as assessed in Mauritius for the corresponding period; Mauritian tax is credited | TUIR, art. 70, c. 2, and 165; treaty, art. 6 and 23 |
| Villa not let | — | No IRPEF on the land income of an unlet property subject to IVIE | DL 201/2011, art. 19, c. 15-ter |
| IVIE | — | 1.06% a year of the cost stated in the purchase deed: €6,360; not due up to €200 | DL 201/2011, art. 19, c. 13 to 16 |
| Resale | No tax on an individual's capital gain; transfer tax of 5% payable by the seller | Capital gain taxable if the resale takes place within five years of purchase | Treaty, art. 13, 1; TUIR, art. 67 |
Rent example
At the 2026-2027 scale, Rs 2,000,000 of taxable net rent, about €37,110, gives Rs 250,000 of Mauritian tax, or 12.5%. In Italy, with no other income, IRPEF on the same sum would be €9,450; after crediting the Mauritian tax (€4,640), €4,810 would remain, excluding additional taxes. Westimmo calculation, €1 = Rs 53.89 on 21 September 2026.
IVIE cannot be offset
It is reduced by any wealth tax paid in the country where the property is located. Do not assume that the registration duty paid once, on purchase, is deducted from it: it is not an annual wealth tax.
Two calendars
Italy taxes by calendar year, Mauritius from 1 July to 30 June. The Italian text refers to the "corresponding tax period": have your Italian adviser align the allocation from the first year.
10 Assets abroad
RW section, IVIE, IVAFE: what must you declare in Italy?
Every Italian resident declares each year, in the RW section, their property, accounts and investments held abroad, and pays two wealth taxes: IVIE on real estate, IVAFE on financial assets. For Mauritius, the IVAFE on investments is doubled and an omission costs more.
Open an account in Mauritius →| Asset held in Mauritius | RW section | Annual tax | Source |
|---|---|---|---|
| Villa or apartment | Yes; no need to repeat while nothing changes, but IVIE remains due | IVIE: 1.06% of the purchase cost; not due up to €200 | DL 167/1990, art. 4; DL 201/2011, art. 19 |
| Current account or savings account | Yes, if the maximum combined value of your accounts abroad exceeds €15,000 in the year | IVAFE: €34.20 per account; not due if the average annual balance does not exceed €5,000 | Same texts; Agenzia delle Entrate page |
| Securities, funds and other financial products | Yes | IVAFE: 4‰ of the value, instead of 2‰ | DL 201/2011, art. 19, c. 20-bis |
| Shares in a Mauritian company | Yes, including as beneficial owner | To be checked according to the nature of the securities; controlled-company rules to be examined (section 14) | DL 167/1990, art. 4; TUIR, art. 167 |
Examples
Villa of €600,000: €6,360 of IVIE a year. Portfolio of €200,000 held in Mauritius: €800 of IVAFE a year, against €400 in a country not on the list. Westimmo calculation, hypothetical amounts.
An omission costs double
A Mauritian asset omitted from the RW section is presumed to be funded by income withheld from taxation, unless proven otherwise; penalties and audit periods are doubled (DL 78/2009, art. 12).
The administration knows
Mauritian banks report to the MRA each year the accounts of Italian residents, which the MRA passes on to Italy under the CRS standard: Italy appears on the list of recipient jurisdictions published by the MRA.
11 Dividends, interest, capital gains
How are your investments taxed between the two countries?
The treaty caps Italian withholding on dividends paid to a resident of Mauritius at 15%, leaves interest to the domestic law of each State and reserves capital gains on securities to the country of residence. For an Italian resident, dividends from a Mauritian company may be taxed at the full scale.
| Income | Resident of Mauritius, Italian source | Italian resident, Mauritian source | Source |
|---|---|---|---|
| Dividends | 26% under domestic law, 15% at most under the treaty; 5% if the recipient is a company directly holding 25% of the capital. Taxed in Mauritius if received there, with credit | No withholding in Mauritius. In Italy: tax of 26%; but dividend taxed in full, at the scale, if it comes from a company under a privileged tax regime | Treaty, art. 10; DPR 600/1973, art. 27; TUIR, art. 18 and 47 |
| Bank interest | Not Italian-source income for a non-resident; taxed in Mauritius if received there | Exempt in Mauritius for a non-resident if paid by an approved bank; 26% in Italy | TUIR, art. 23, 1, b, and 18 |
| Other interest | Italian withholding under domestic law, with no treaty cap | Domestic law of each State; credit within the limit of article 23 | Treaty, art. 11 |
| Capital gains on shares and units | Taxable in Mauritius only, which does not tax an individual's capital gain | Taxable in Italy only; 26% for financial capital gains | Treaty, art. 13, 3; DL 66/2014, art. 3 |
Obtaining the 15%
On a dividend of €10,000 paid by an Italian company, domestic withholding is €2,600; the treaty limits it to €1,500. The excess is claimed from the Italian administration, with an MRA residence certificate (art. 28).
The privileged regime, company by company
Absent control on your part, a company falls under a privileged regime if its nominal level of taxation is less than half the Italian level, special regimes included (TUIR, art. 47-bis). Italian corporate tax (IRES) is 24%; the Mauritian nominal rate of 15% exceeds half of it, but a company benefiting from the 80% partial exemption on certain foreign income must be analysed.
No credit on a flat tax
Income subject in Italy to the 26% substitute tax gives entitlement to no foreign tax credit. You may waive it: the income then moves to the scale, with the tax credit (TUIR, art. 18; treaty, art. 23).
12 Retirement and pensions
How is your Italian pension taxed in Mauritius?
A pension from private employment is taxable only in Mauritius, provided it is subject to tax there; a civil service pension remains taxable in Italy only. Other pensions are characterised one by one. INPS applies the treaty only on request.
Retiring in Mauritius →| Pension | What the treaty provides | In practice | Source |
|---|---|---|---|
| Pension of a former private-sector employee | Taxable in Mauritius only | Provided it is subject to tax there: otherwise Italy may tax it. Mauritius taxes the pension received there | Art. 18, 1 and 2 |
| Civil service pension (State, local authorities) | Taxable in Italy only | Unless you hold Mauritian nationality and are resident in Mauritius: Mauritius only. | Art. 19, 2; protocol |
| Pension of a self-employed person, craftsman, trader or professional fund | Article 18 if it rewards past employment; otherwise "other income", taxable in the State of residence only | Characterisation to be confirmed with the paying body | Art. 18 and 22 |
| End-of-service indemnity (TFR), retirement lump sum | Italian law treats them as Italian-source income; their treaty characterisation is to be checked | To be analysed before payment | TUIR, art. 23, c. 2, a |
| Private annuity, survivor's pension | Characterisation to be checked, according to the contract or the original pension | — | Art. 18, 19 and 22 |
The clause in article 18, 2
Mauritius's exclusive right falls away if the recipient is not subject to tax on that pension under Mauritian law. Yet Mauritius taxes foreign income only if it is received there (Income Tax Act, s. 5(3)). Our reading of the text: a pension left in an Italian account is not taxed in Mauritius and remains exposed to Italian tax. Have it confirmed before choosing the account into which it is paid.
The request to INPS
According to INPS, pensions paid to a non-resident are, as a general rule, taxable in Italy: the treaty applies only on request, using form EP-I (EP-I/2 in Italian and French), with the MRA residence certificate. Failing that, IRPEF at the scale: €5,520 on a pension of €24,000, before the tax reductions provided for pensions.
On the Mauritian side
The Income Tax Act treats pensions from past employment and other annuities and pensions as income (s. 10(1)(a)(ii) and (d)). Received in Mauritius, a pension of €24,000, about Rs 1,293,000, bears Rs 108,678 of tax at the 2026-2027 scale, or 8.4%. A lump sum is not a pension: section 5(3) covers foreign income, it does not make a lump sum taxable because it is transferred.
13 Estates and gifts
Who taxes an estate between Italy and Mauritius?
Italy looks at the residence of the deceased or the donor, not that of the heir. Italian resident: all their assets are taxed, Mauritian villa included. Resident of Mauritius: only their assets located in Italy are. Mauritius has no general inheritance tax, but a transmitted Mauritian property may be subject to registration duties or transfer taxes.
| Situation | Italy | Mauritius |
|---|---|---|
| Deceased resident in Italy | All assets and rights transmitted, even if located abroad: Mauritian villa and accounts included | No general tax; registration duties or transfer tax possible on the Mauritian property, subject to exemptions |
| Deceased resident in Mauritius, assets in Italy | Only the assets and rights located in Italy | No general tax |
| Deceased resident in Mauritius, assets outside Italy | Nothing, even if the heir lives in Italy | No general tax; duties possible on a Mauritian property |
| Gift | Same rule, according to the donor's residence; foreign tax paid on the same gift is credited for assets located abroad | A gift of Mauritian property goes through a notarial deed |
Rates and allowances in Italy
| Beneficiary | Rate | Allowance per beneficiary |
|---|---|---|
| Spouse, children, direct-line parents | 4% | €1,000,000 |
| Brothers and sisters | 6% | €100,000 |
| Other relatives up to the fourth degree, in-laws | 6% | None |
| Other persons | 8% | None |
| Severely disabled beneficiary | Rate of their category | €1,500,000 |
Example
A child receives €1,600,000: 4% on €600,000, i.e. €24,000. For Italian property, the mortgage tax of 2% and the cadastral tax of 1% are added. The return is filed within twelve months of death; since 2025, the heir calculates the tax themselves.
The deceased's residence
The presumption of residence of Italian citizens who have left for Mauritius is written for income taxes; the inheritance text speaks only of a "non-resident" deceased. Do not assume that AIRE settles the question: have it analysed by an Italian notary.
No inheritance treaty
The 1990 treaty covers only income taxes. In Mauritius, the absence of a general inheritance and gift tax erases neither the registration duties and transfer taxes possible on a property, nor the formalities: deed of notoriety and declaration with a notary. Westimmo works with Mauritian notaries.
14 Companies and entrepreneurs
Owning or managing a company between Italy and Mauritius?
A Mauritian company managed from Italy becomes resident there and pays Italian corporate tax, 24%. Controlled by an Italian resident, it may fall under the controlled foreign companies regime. Conversely, managing your Italian company from Mauritius does not take it out of Italy.
Buying through a company →| Rule | What it provides | Source |
|---|---|---|
| Residence of a company | Italian resident if, for the greater part of the period, it has in Italy its registered office, its place of effective management or its main ordinary management. | TUIR, art. 73, c. 3 |
| Presumption concerning foreign companies | A foreign company controlling an Italian company is presumed to be an Italian resident if it is controlled by Italian residents or administered in the majority by them; proof to the contrary admitted | TUIR, art. 73, c. 5-bis |
| Dual residence of a company | The treaty retains the place of effective management | Treaty, art. 4, 3 |
| Controlled foreign companies (CFC) | The regime also covers individuals. Control, or more than 50% of profits; two cumulative conditions: effective taxation below 15% based on audited accounts — failing that, below half of Italian taxation — and more than a third of passive income | TUIR, art. 167 |
| Dividends from a privileged regime | Taxed in full at the recipient's scale, unless credit has already been given under the CFC rules or proof of genuine economic activity | TUIR, art. 47, c. 4, and 47-bis |
| Permanent establishment | A construction or assembly site constitutes one beyond six months; a place of management, a branch or an office also | Treaty, art. 5 |
The Mauritian rate of 15%
The Mauritian nominal corporate rate is 15%; what matters for the Italian controlled-company regime is the tax actually borne, after exemptions. A Mauritian company benefiting from the 80% partial exemption on certain foreign income may fall below the thresholds: the analysis is done company by company.
You manage from Mauritius
Your Italian company keeps its registered office in Italy: it remains an Italian resident and taxed in Italy, at 24%. Your dividends bear withholding of 15% at most; your director's remuneration may remain taxed in Italy (art. 16).
Buying through a company
A Mauritian company holding your villa does not erase the RW section or the rules above: it moves them. Compare with buying in your own name before signing.
15 Transfers and declarations
Transferring your money, declaring, and what the administrations exchange
A transfer is not income: wiring to Mauritius the price of a flat sold or your savings creates no tax in itself. What matters is the nature of the sum and the year in which it was earned. The two administrations, for their part, exchange their information.
Declaring on arrival →| Sum wired to Mauritius | Nature | In Mauritius |
|---|---|---|
| Sale price of an Italian apartment | Capital; any capital gain falls to Italy | No tax |
| Savings built up before arrival | Capital | No tax |
| Italian rent, dividend or interest of the year | Foreign income | Taxable when received, with credit for Italian tax |
| Italian pension | Foreign income | Taxable when received; this is also what rules out Italian tax on a private-sector pension (section 12) |
| End-of-service indemnity, retirement lump sum | Characterisation to be checked | Not decided by the transfer alone |
No exchange control in Mauritius
According to the Bank of Mauritius, it was abolished in July 1994. The bank and the notary verify the origin of funds: prepare the deed of sale, statements and supporting documents.
The exchange of information
Three channels: article 26 of the treaty, rewritten in 2010, against which bank secrecy cannot be invoked; the OECD and Council of Europe multilateral convention (Italy since 2006, Mauritius since 2015); the CRS standard, under which Mauritian banks report the accounts of Italian residents. The bilateral treaty provides no assistance in the collection of taxes; this guide does not cover that of the multilateral convention.
In Mauritius
Tax number (TAN) with the MRA; return for the year ended 30 June by 15 October at the latest, payment included. Declaring on arrival →
16 Practical cases
Four common situations
Four profiles we often meet. Hypothetical amounts, no other income or tax reduction, excluding Italian additional taxes.
| Situation | What applies |
|---|---|
| An entrepreneur, an Italian citizen, settles in Mauritius; he keeps his company and a let apartment in Milan | Residence: even if registered with AIRE, he remains presumed to be an Italian resident. He must prove that he has moved family, home and business, otherwise Italy taxes all his income. Exit tax: his shares, held privately, are outside the scope of article 166. Company: it remains Italian, taxed at 24%; its dividends bear 15% instead of 26%. Apartment let for €14,400 a year: €3,024 under cedolare secca, IMU in addition. |
| A retired private-sector employee moves to Mauritius with a pension of €24,000 and keeps an account in Italy | Pension: taxable in Mauritius only (art. 18, 1), provided it is subject to tax there. She asks INPS to apply the treaty and has her pension paid in Mauritius: Rs 108,678 of Mauritian tax, about €2,020, against €5,520 of IRPEF in Italy before reductions. Pension left in the Italian account: not taxed in Mauritius, therefore exposed to Italian tax (art. 18, 2). Estate: resident in Mauritius at death, only her Italian assets would be taxed in Italy. |
| A couple remains Italian resident and buys a €600,000 villa in Grand Baie, let for part of the year | Purchase: €30,000 of registration duty in Mauritius; residence permit possible. Each year: IVIE of €6,360, villa in the RW section. Rent: Rs 250,000 of Mauritian tax on Rs 2,000,000 of net rent; Italy deducts the Mauritian tax, leaving about €4,810 due. Resale within five years: capital gain taxable in Italy. |
| A wealthy family, Italian resident, holds in Mauritius a €2,000,000 portfolio and a holding company | Portfolio: IVAFE at 4‰, i.e. €8,000 a year. Company: controlled by Italian residents, it falls under the controlled foreign companies regime if its effective taxation is below 15% and more than a third of its income is passive. Dividends: taxed in full at the scale, up to 43%, if the company falls under a privileged regime. Estate: the whole estate is taxed in Italy, at 4% above €1,000,000 per child. |
17 Related guides
To go further
The main guide and the pages detailing each subject on the Mauritian side.
International Taxation & MauritiusThe main guide, country by country→
Investing in MauritiusMeasured yields and simulators→
Purchase costsThe real cost of a purchase, line by line→
Tax on rentThe scale applied, worked examples→
Visas, permits and residenceAll the routes to live in Mauritius→
Living in MauritiusPreparing your departure and your first year→18 Sources & methodology
Reliable, up-to-date information
Every rule comes from the treaty, from a statute read in its version in force, or from an official publication of the Italian or Mauritian administrations, read on 5 October 2026.
Agenzia EntrateItalian tax administrationNormattivaItalian laws in forceMRAMauritius Revenue AuthorityTreatyItaly–Mauritius, 1990
- Convention between Italy and Mauritius signed in Port Louis on 9 March 1990 (Italian law no. 712 of 14 December 1994, in force on 28 April 1995) and protocol of 9 December 2010 (law no. 166 of 31 August 2012, in force on 19 November 2012): texts published by the Italian Ministry of Economy and Finance and by the MRA
- OECD: signatories and parties to the MLI at 15 September 2026; multilateral convention on administrative assistance. MRA: list of treaties in force, list of CRS jurisdictions
- Consolidated income tax act (DPR 917/1986), read on Normattiva in its version in force on 5 October 2026: art. 2, 11, 18, 23, 24, 37, 47, 47-bis, 67, 70, 73, 77, 165, 166, 167 and 169; Legislative Decree no. 117 of 19 June 2026, which replaces it on 1 January 2027
- Ministerial decree of 4 May 1999 (copy from the Agenzia delle Entrate); circular 20/E of 4 November 2024 on residence; DL 201/2011, art. 19 (IVIE, IVAFE); DL 167/1990, art. 4 (RW section); DL 78/2009, art. 12
- D.Lgs. 23/2011, art. 3, and circular 26/E of 2011 (cedolare secca); DL 50/2017, art. 4; DPR 600/1973, art. 27 and 75; DL 66/2014, art. 3; law 160/2019, art. 1, c. 745, 754 and 755 (IMU); D.Lgs. 446/1997, art. 50, and D.Lgs. 360/1998, art. 1 (additional taxes to IRPEF); law 470/1988, art. 1 (AIRE); law 266/2005, art. 1, c. 496; Consolidated Act on Inheritance and Gift Tax (D.Lgs. 346/1990), art. 2, 7 and 56; INPS, pensions paid abroad
- Mauritius: Finance Act 2026, art. 7(v); Income Tax Act, s. 5(3), 10(1) and 77, Second Schedule; MRA; Bank of Mauritius: exchange control abolished in July 1994
Texts read and verified on 5 October 2026. The Italian rates cited are those of 2026. The worked examples do not include the regional and municipal surcharges to IRPEF, whose rate depends on the region and the municipality; the incentive schemes for arriving in Italy, which concern a return and not a departure, are outside the scope of this guide. This guide sets out the rules of both countries; it does not replace the advice of a tax adviser, in Italy as in Mauritius, on your situation.
19 Frequently asked questions
Your questions on taxation between Italy and Mauritius
Short answers, backed by official texts.
Frequently asked questions: Italy ↔ Mauritius
Yes: signed in Port Louis on 9 March 1990, in force since 28 April 1995 and amended by the 2010 protocol. It covers only income taxes: neither IVIE, nor IVAFE, nor estates.
No, not to date. Italy signed it in 2017 but has not deposited its instrument of ratification, according to the status published by the OECD at 15 September 2026. The treaty is therefore read in its 1990 text, as amended in 2010.
Mauritius appears on the list in the ministerial decree of 4 May 1999. Consequences: presumption of residence for Italian citizens who settle there, IVAFE at 4‰ on investments held there, presumption and doubled penalties for undeclared assets.
No. It rules out the presumption linked to the population register, not domicile, civil residence or physical presence. And an Italian citizen settled in Mauritius remains presumed to be resident, unless proven otherwise.
No. The criteria are alternative: if your personal and family relations remain in Italy for the greater part of the year, your domicile is there, whatever the number of days.
Article 166 of the consolidated act targets those who carry on a commercial business; securities held privately do not fall within its scope. Have your situation analysed all the same before leaving, especially if you manage a company.
In Italy: at the IRPEF scale on rent reduced by 5%, or at the cedolare secca of 21% by option. Mauritius taxes it only if it is received there, deducting the Italian tax.
In Italy, if the property was bought or built five years ago or less: at the scale, or at 26% by option before the notary. A property received by inheritance is not covered. Mauritius does not tax this capital gain.
Pension from private employment: in Mauritius only, provided it is subject to tax there, and therefore received there. Civil service pension: in Italy only, unless Mauritian nationality. The request is made to INPS, using form EP-I.
Yes: in the RW section, and you pay IVIE, 1.06% a year of the purchase price. Rent is taxed in Mauritius and then in Italy, which deducts the Mauritian tax.
Yes, through IVAFE: €34.20 per account if the average annual balance exceeds €5,000, and 4‰ of the value for securities and other financial products held in Mauritius. Accounts are declared in the RW section above €15,000.
Italy taxes according to the deceased's residence: all their assets if they resided in Italy, only their Italian assets otherwise; 4% above €1,000,000 per child or spouse. Mauritius has no general inheritance tax, but duties may apply to a property.