Treaty signed in London on 11 February 1981, amended in 1986, 2003, 2011 and 2018, then by the MLI since 2021: it covers neither British inheritance tax nor Mauritian duties
International taxation & Mauritius
United Kingdom ↔ Mauritius
Who taxes your rent, your capital gains, your pensions and your estate between the United Kingdom and Mauritius.
The 1981 treaty, as amended by its protocols and by the OECD multilateral instrument, read in its text currently in force, and British law after the 2025 reform: whether you are leaving the United Kingdom or investing in Mauritius while remaining resident here.
Leaving the United Kingdom
is proved day by day
is proved day by day
The essentials
Four rules to know before leaving or buying.
Leaving is not enough: British residence is lost under the Statutory Residence Test (SRT), and returning within five years makes gains realised in the meantime taxable in the year of return
Private British pension: taxable in Mauritius only, but only on the part you receive there; civil service or local authority pension: in the United Kingdom only, unless you are a Mauritian national without being British
Since 6 April 2025, inheritance tax follows long-term residence, no longer domicile: it can follow you for up to ten years after you leave
01 In brief
Who taxes what between the United Kingdom and Mauritius?
Everything depends on your tax residence. Profile A: you leave the United Kingdom to settle in Mauritius. Profile B: you remain UK tax resident and invest in Mauritius. One table for each.
Profile A — you have become a resident of Mauritius
| Income or asset | Where it is taxed | What you need to know | Text |
|---|---|---|---|
| Unrealised gains on departure | Nowhere on departure | The United Kingdom has no exit tax for individuals; a return within five years makes gains realised during the absence taxable | TCGA 1992, s. 10A; treaty, art. 13, 5 |
| Rent from a property in the United Kingdom | In the United Kingdom; in Mauritius if received there | 20% withholding by the agent or tenant, unless HMRC agrees otherwise (NRL1i) | Treaty, art. 6; non-resident landlord scheme |
| Sale of that property | In the United Kingdom | Return and payment within 60 days, even with no gain; 18% or 24% | Treaty, art. 13, 1; NRCGT |
| Shares in a company that is 75% UK property-rich | In the United Kingdom | Under domestic law, for a holding of at least 25%; the treaty does not prevent it | NRCGT, indirect disposals |
| Other shares and funds | In Mauritius only, which does not tax capital gains | Unless you return to the United Kingdom within five years | Treaty, art. 13, 4 and 5 |
| Pension from an employer or private scheme, annuity | In Mauritius only | But the British exemption covers only the part received in Mauritius | Treaty, art. 18 and 23 |
| Civil service or local authority pension | In the United Kingdom only | Unless you are a Mauritian national without being British | Treaty, art. 19, 1 |
| State Pension | In Mauritius if taxed there | Uprated each year in Mauritius | Treaty, art. 22; 1981 Order |
| Estate | In the United Kingdom: British assets; all your wealth if you are a long-term resident | No inheritance tax treaty; Mauritius levies no duty | IHTA 1984, reform of 6 April 2025 |
Profile B — you remain UK tax resident and invest in Mauritius
| Income or asset | Where it is taxed | What you need to know | Text |
|---|---|---|---|
| Rent from your Mauritian property | In Mauritius, then in the United Kingdom | The United Kingdom credits the Mauritian tax, up to the limit of its own tax on that rent | Treaty, art. 6 and 24, 1 |
| Capital gain on resale | In the United Kingdom, 18% or 24% | Mauritius does not tax it; its transfer tax is not a covered tax | Treaty, art. 2 and 13 |
| Dividends from a Mauritian company | In the United Kingdom | Mauritius withholds nothing; 10.75%, 35.75% or 39.35% in the United Kingdom | Treaty, art. 10; FA 2026, s. 4 |
| New arrival in the United Kingdom | Possible exemption for four years | FIG regime, in exchange for losing the year's allowances | FA 2025; HMRC, FIG regime |
| Estate and gifts | In the United Kingdom | Mauritian villa included if you are a long-term resident | IHTA 1984 |
| Transfer of funds | No exchange controls | Neither in the United Kingdom nor in Mauritius; origin of funds checked by the bank | Bank of Mauritius |
02 The treaty
What does the tax treaty between the United Kingdom and Mauritius contain?
Signed in 1981, it has been amended four times by protocol, then by the OECD multilateral instrument (MLI). Today's text is therefore not the original: dividends, the gains of former residents and the exchange of information have been rewritten.
| Step | Date or content | Reference |
|---|---|---|
| Signature | 11 February 1981, in London; replaces the 1947 arrangement | SI 1981/1121 |
| Application | United Kingdom: income tax and capital gains tax from 6 April 1982; Mauritius: from the year starting on 1 July 1982 | Art. 30 |
| 1986 Protocol | Signed on 23 October 1986 | Consolidated text |
| 2003 Protocol | Signed on 27 March 2003, in force on 22 October 2003: new article 13, 5 on the gains of former residents | 2003 Protocol |
| 2011 Protocol | Signed on 10 January 2011, in force on 13 October 2011: exchange of information, bank secrecy not opposable | Art. 28 |
| 2018 Protocol | Signed on 28 February 2018, in force on 13 July 2018: new article 10 on dividends | Art. 10 |
| Multilateral instrument (MLI) | In force for the United Kingdom on 1 October 2018, for Mauritius on 1 February 2020; in the United Kingdom, effective from 6 April 2021 for income tax and capital gains tax | Positions of both States; synthesised texts |
| What the MLI changes | Preamble against non-taxation (art. 6), general anti-abuse rule (art. 7, 1), mutual agreement procedure (art. 16), corresponding adjustments (art. 17), mandatory arbitration, with Mauritius's reservations | Synthesised texts from HMRC and the MRA |
| Taxes covered | British income tax, corporation tax and capital gains tax; Mauritian income tax; neither British inheritance tax nor registration duties | Art. 2 |
What the treaty does not contain
No clause on property-rich companies, no article on estates, no assistance in the collection of taxes. What the treaty does not govern falls under the domestic law of each State.
Synthesised texts are not authoritative
HMRC and the MRA publish a text incorporating the MLI, a mere reading aid. HMRC's text labels the anti-abuse clause “article 17”, which is article 7 of the MLI. The two agree in substance.
The anti-abuse clause
A treaty benefit is denied if obtaining it was one of the principal purposes of an arrangement, unless granting it remains in accordance with the object and purpose of the treaty (MLI, art. 7, 1).
03 Tax residence
Who is UK tax resident, and who is Mauritian tax resident?
Since 2013 the United Kingdom has applied a Statutory Residence Test (SRT): automatic tests, then a day count cross-referenced with your ties. Mauritius counts days. If both States treat you as resident, article 4 of the treaty decides.
The day count in Mauritius →| Step | You are non-resident if… | You are resident if… |
|---|---|---|
| 1. Automatic overseas tests | Fewer than 16 days in the United Kingdom (resident in one of the three previous years); fewer than 46 days (resident in none); full-time work abroad, fewer than 91 days in the United Kingdom of which fewer than 31 days with more than three hours' work | — |
| 2. Automatic UK tests | — | 183 days or more; a home in the United Kingdom for 91 consecutive days, occupied for at least 30 days, with no home abroad or almost none; full-time work in the United Kingdom |
| 3. Sufficient ties | Not enough ties for your number of days | Enough ties for your number of days (table below) |
| Days in the United Kingdom in the year | Resident in one of the three previous years | Resident in none |
|---|---|---|
| 16 to 45 | 4 ties | Always non-resident |
| 46 to 90 | 3 ties | 4 ties |
| 91 to 120 | 2 ties | 3 ties |
| More than 120 | 1 tie | 2 ties |
If both States treat you as resident
Mauritius
A person is resident in Mauritius if they spend 183 days there in the income year, or 270 days over that year and the two previous ones, or have their domicile there. The foreign income of an individual is taxed there only if received in Mauritius.
Article 4, 2
Permanent home, then centre of vital interests, then habitual abode, then nationality, then agreement between the authorities. A house kept available to you in England is a permanent home: with a home in Mauritius, the question moves to vital interests.
Resident of Mauritius within the meaning of the treaty
The MRA tax residence certificate is the usual proof to HMRC and British payers; it relates to the application of the treaty, not to the SRT.
04 Leaving the United Kingdom
How do you cease to be UK resident?
Neither physically leaving, nor a Mauritian residence permit, nor form P85 ends UK residence on its own: it is the SRT, applied to each tax year (6 April to 5 April), that decides. The year of departure can be split in two if you meet all the conditions of one of the cases provided for.
| Case | Situation | Main conditions |
|---|---|---|
| Case 1 | You start full-time work abroad | Resident in the year and the previous year; non-resident in the following year under the full-time work abroad test; work criteria met over the period |
| Case 2 | You accompany your spouse or partner who falls under case 1 | Living with them abroad; conditions specific to case 2 (RFIG21090) |
| Case 3 | You cease to have any home in the United Kingdom | Resident in the year and the previous year, non-resident in the following year; then fewer than 16 days in the United Kingdom and, within six months, tax residence in a country, presence there every evening for six months, or your only home in that country |
| Step | When | What it does, and does not do |
|---|---|---|
| Form P85 | On departure, if you do not file a return | Informs HMRC and allows a refund; unnecessary if you file a return; does not decide your residence |
| SA109 pages of the return | Return for the year of departure and subsequent years | Declare non-residence, the split year, the days and the ties |
| Form NRL1i | Before receiving rent as a non-resident | Allows rent to be received without withholding, with HMRC’s agreement |
| Form DT-Individual | For each private pension | Endorsed by the MRA, it allows HMRC to stop British withholding (NT code) |
| International Pension Centre | Before or after departure | To receive the State Pension in Mauritius |
Keeping ties
A house kept, a spouse who stayed in the United Kingdom, work of more than 40 days, more than 90 days spent in one of the two previous years: each tie lowers the number of days beyond which you remain resident. Keep a record of your days from the moment you leave.
Split year: all the conditions
Each case has its own conditions, and you must meet them all. Without a split year, you remain resident for the whole year, worldwide income included.
What does not change
Tax residence affects neither British nationality nor your British passport; nor does it erase long-term residence for inheritance tax purposes (section 13).
05 2025 reform
The end of non-dom status: what changed on 6 April 2025
The reform separated three things that the old status mixed together: residence, which remains that of the SRT; the taxation of foreign income, which moves to the four-year FIG regime; and inheritance tax, which now follows long-term residence. Any source that still speaks of domicile or the remittance basis for the future describes the old regime.
| Subject | Until 5 April 2025 | Since 6 April 2025 |
|---|---|---|
| Foreign income and gains | Remittance basis: the non-domiciled person was taxed only on what they remitted | FIG regime: exemption for the first four years of residence after ten years of absence; then worldwide taxation |
| What counts | Domicile, a civil-law concept | Tax residence, year by year |
| Estate | Domicile or deemed domicile | Long-term residence: ten of the previous twenty years |
| Foreign income accumulated before 2025 | Taxed if remitted | Still taxed if remitted during a year of residence; reduced-rate Temporary Repatriation Facility (TRF) |
| Designation year | Rate | Who can use it |
|---|---|---|
| 2025-26 and 2026-27 | 12% | Anyone who used the remittance basis before 6 April 2025 |
| 2027-28 | 15% | Same condition |
| Afterwards | End of the scheme | Return to ordinary law |
The FIG regime
It covers foreign employment and property income, dividends, interest and foreign gains; not salaries. The claim is made in the tax return, source by source, and costs the year’s income tax and capital gains allowances. The four years run from arrival and cannot be carried forward.
And if you leave for Mauritius?
As a non-resident, you are no longer taxed in the United Kingdom on your foreign income: the FIG regime and the TRF no longer concern you. The TRF can only be designated in a return for a year of residence. But remitting old income during a temporary non-residence makes it taxable in the year of return (section 06).
Returning after ten years
A British person settled in Mauritius for at least ten full tax years who returns to the United Kingdom is a new arrival: they may claim the FIG regime for their first four years.
06 Capital gains
Does leaving for Mauritius wipe out capital gains tax?
Not automatically. The United Kingdom has no exit tax for individuals: it taxes the gains of residents, and those of non-residents on British property. But a return within five years makes gains realised during the absence on assets held at departure taxable in the year of return.
| Point | Rule | Consequence |
|---|---|---|
| Who is covered | Only those UK resident in four of the seven tax years before departure | Most expatriates leaving the United Kingdom |
| Duration | Non-residence of five years or less; five years and a day are needed to escape it | Left on 4 May 2015, returned on 4 May 2020: the rule does not apply |
| What is taxed on return | Gains on assets held at departure, distributions from close companies, certain pension lump sums, remitted foreign income | In the year of return, as if you had never left |
| What in principle escapes it | Assets acquired after departure and sold during the absence | To be checked asset by asset |
| From 2026-27 | Payments received through interposed companies | A shell-company arrangement no longer protects |
| The treaty | Each State keeps its domestic law on a person who was resident there in the year of disposal or one of the six previous years | The treaty does not neutralise the British rule |
Mauritius does not tax capital gains
Mauritius levies no capital gains tax on an individual. A sale made in Mauritius, followed by a return to the United Kingdom within five years, therefore gives rise to British tax with nothing to deduct.
The rates
18% in the basic-rate band, 24% above it, since 6 April 2025, residential property included; 18% for Business Asset Disposal Relief (BADR) since 6 April 2026; annual exempt amount of £3,000.
Planning
The date of sale, the actual length of the absence and the date of return decide everything. A plan to return is costed before the sale, not after.
07 A property kept in the United Kingdom
What happens to the home you keep in the United Kingdom?
Its rent remains taxed in the United Kingdom, as does its sale, and it remains in your British estate whatever your country of residence. The rules are not uniform: the tax on purchases differs between England, Scotland, Wales and Northern Ireland.
| Event | British taxation | Mauritian side |
|---|---|---|
| Rent | Declared in the United Kingdom (SA105), expenses deductible; personal allowance of £12,570 for a British citizen or under the treaty | Taxed if received in Mauritius, British tax credited |
| Withholding | Absent six months or more: the agent, or the tenant above £100 per week, withholds tax at the basic rate, unless NRL1i is approved | — |
| Rate of tax on rent | 20%, 40%, 45% in 2026-27; 22%, 42%, 47% from 2027-28 | — |
| Sale | Return and payment within 60 days, even with no gain; 18% or 24%; gain calculated from 5 April 2015 if the property was held before then | No capital gains tax |
| Former main residence | Possible main residence relief, depending on periods of occupation | — |
| Death | The property enters the British estate, whether or not you are a long-term resident | Mauritius levies no duty |
| Tax | England and Northern Ireland | Scotland | Wales |
|---|---|---|---|
| Income tax of a non-resident | UK rates | UK rates: only a resident can be a Scottish taxpayer | UK rates: only a resident can be a Welsh taxpayer |
| Income tax of a resident | UK rates | Rates set by the Scottish Parliament; own property rates possible | Welsh rates; own property rates possible |
| Purchase duty | SDLT, with a 2% surcharge for the non-resident buyer | LBTT, with no non-resident surcharge | LTT, with no non-resident surcharge |
| Capital gains and estate | UK-wide taxes | Same | Same |
Why there is no single rate
The property rates of 22%, 42% and 47% apply to England and Northern Ireland; Scotland and Wales may set their own for their residents (FA 2026, s. 8). A non-resident landlord, for his part, is neither Scottish nor Welsh for tax purposes: he falls under UK rates, wherever his property is.
Holding through a company
A company holding the property pays corporation tax, and its shares fall within NRCGT if it is 75% UK property-rich and you hold 25%. Shares in a British company are British assets: they remain in your estate. Have it costed before restructuring.
The paper return
The non-resident landlord files the full return every year, with pages SA105 and SA109: by 31 October on paper, by 31 January online.
08 Investing in Mauritius
You buy in Mauritius while remaining UK resident: who taxes what?
Two distinct questions: what Mauritius taxes, as the State where the property is located; what the United Kingdom, as the State of residence, then taxes, taking Mauritian tax into account. The treaty removes neither: it organises a credit.
Tax on rent in Mauritius →What Mauritius can tax
On purchase
5% registration duty and notary fees; a property of at least USD 375,000 bought under a scheme opens a residence permit. These duties are not income taxes: the treaty does not cover them and the United Kingdom gives no credit for them. Purchase costs →
Rent
It is taxable in Mauritius (art. 6), at the progressive rates; a tenant who is not an individual withholds 10% at source. Rs 2,000,000 of net rent gives Rs 250,000 of tax, i.e. 12.5%.
Resale
Mauritius does not tax the capital gains of an individual. The seller pays 5% transfer tax, outside the treaty. Reselling →
What the United Kingdom then taxes
Rent
Converted into pounds, Mauritian rent enters your worldwide income, at property rates (22%, 42%, 47% from 2027-28 for England and Northern Ireland). The United Kingdom credits Mauritian tax, up to the limit of the British tax due on that same rent (art. 24, 1). The excess is lost.
The capital gain
Taxed at 18% or 24% after the £3,000 allowance. As Mauritius has levied nothing on the gain, nothing is credited; the transfer tax cannot be set against it as a tax. As a long-term resident, the villa also enters your British estate (sections 13 and 14).
The new arrival case (FIG regime)
Having arrived in the United Kingdom after at least ten years of non-residence, you may, for four years, claim exemption for your Mauritian rent and gains, even if remitted. In exchange: loss of the year’s income tax and capital gains allowances. Mauritius still taxes the rent.
09 Investments
Dividends and interest: who taxes what?
Since the 2018 protocol, the United Kingdom can no longer tax at source ordinary dividends paid to a resident of Mauritius (art. 10, 2, a). Exception (art. 10, 2, b): dividends derived, directly or not, from immovable property income and paid by an investment vehicle that distributes most of it each year and whose such income is exempt, such as a REIT or a PAIF, remain taxable in the United Kingdom, at no more than 15% of the gross amount; the exemption applies to them only if the beneficiary is a pension fund established in Mauritius. Interest, for its part, remains taxable in both States, with no treaty cap.
| Income | Profile A: you live in Mauritius | Profile B: you live in the United Kingdom |
|---|---|---|
| Ordinary dividends from a British company | Exempt in the United Kingdom (art. 10, 2, a); in Mauritius if received there | 10.75%, 35.75% or 39.35% from 2026-27 |
| Property dividends from a British REIT or PAIF | Taxable in the United Kingdom, at no more than 15% of the gross (art. 10, 2, b), except a Mauritian pension fund; in Mauritius if received there | Taxed in the United Kingdom |
| British interest | Taxable in the United Kingdom and in Mauritius if received there, with no cap; exempt at source if paid by the State or certain bodies | At savings rates |
| Dividends from a Mauritian company | In Mauritius if received there | In the United Kingdom; Mauritius withholds nothing |
| Capital gains on securities | Mauritius only, which does not tax, unless you return within five years | 18% or 24% |
Bank interest
British banks pay interest without withholding. The treaty lets the United Kingdom tax the British interest of a resident of Mauritius, with no cap (art. 11); what British law actually levies on it depends on your situation, which should be checked. Mauritius taxes this interest if received there and credits the British tax.
The personal allowance
A resident of Mauritius may obtain the British personal allowances, unless their British income consists only of dividends, interest or royalties (art. 25, 3); a British citizen is entitled to them in any case.
Do not mix the regimes
The 10.75% rate on dividends applies to a British taxpayer; it says nothing about the Mauritian tax of a resident of Mauritius.
10 Companies and trusts
Do you keep a company or a trust in the United Kingdom?
These situations almost always call for advice from an adviser, on both sides. Here are the points where they tip over.
Buying through a company in Mauritius →The shares of your Ltd
No taxation on departure. Sold after more than five years of absence, and if the company is not 75% UK property-rich, they fall under Mauritius only, which does not tax capital gains. Sold earlier, or distributed as dividends from a close company during the absence, they are taxed in the year of return.
Managing the company from Mauritius
A company whose effective management moves to Mauritius may become resident in Mauritius within the meaning of the treaty (art. 4, 3). The British consequences of such a transfer are heavy: decide nothing without advice.
Trusts
Trust income is excluded from the article on other income (art. 22, 3). Since 2025, the status of trust assets for inheritance tax follows the settlor’s long-term residence; a cap on charges exists for assets placed before 30 October 2024 (FA 2026, s. 74). Have each trust examined.
11 Retirement and pensions
Where is your British pension taxed?
There is no single “British pension”, but several schemes, and the treaty treats them differently. A private pension or annuity falls under Mauritius alone, but the British exemption covers only what you receive in Mauritius. A public pension remains taxable in the United Kingdom only, unless you are a Mauritian national without being British (art. 19, 1). The State Pension follows the article on other income.
| Pension | Article | United Kingdom | Mauritius |
|---|---|---|---|
| Employer pension (occupational scheme) for past employment | Art. 18, 1 | Exempt under the treaty, for the part received in Mauritius | Taxes it if received there |
| Personal pension (SIPP, individual contract), life annuity | Art. 18, 1 and 2 | Same | Same |
| Civil service or local authority pension | Art. 19, 1 | Sole right to tax, unless you are a Mauritian national without being British | Only in that case: the pension then falls under Mauritius alone, like a private pension (art. 18) |
| Pension from a state-owned enterprise carrying on commercial activity | Art. 19, 3 | Like a private pension | Like a private pension |
| State Pension | Art. 22 | Exempt if taxed in Mauritius; in general, no British tax for a non-resident | Taxes it if received there |
Why “the part received in Mauritius”
Mauritius taxes the foreign income of an individual when it is received there (s. 5(3)). Article 23 then limits the British exemption to the part received in Mauritius. A private pension left in a British account may therefore be taxed in the United Kingdom. To stop British withholding, have form DT-Individual endorsed by the MRA.
The State Pension in Mauritius
Mauritius is bound to the United Kingdom by the 1981 social security agreement: the pension is uprated each year there (1981 Order, art. 4, 2). Have this confirmed by the International Pension Centre for the new State Pension. The transfer in rupees costs 0.39% in conversion fees.
No healthcare agreement
The United Kingdom has no reciprocal healthcare agreement with Mauritius: arrange health insurance.
12 Lump sums and transfers
Pension lump sum, transfer abroad and QROPS
An annuity and a lump-sum withdrawal are not treated in the same way. On the British side, 25% of the capital comes out tax-free; on the Mauritian side, a capital sum is not income merely because it is transferred, but no exemption is automatic for a foreign fund. A pension transfer abroad is never automatically exempt.
| Transaction | United Kingdom | Mauritius |
|---|---|---|
| 25% tax-free lump sum | Exempt, up to £268,275 over a lifetime | Characterisation to be confirmed; the Rs 3,000,000 exemption applies to a fund approved in Mauritius |
| Rest of the capital, partial withdrawals | Taxable in the United Kingdom; treaty exemption possible “in certain circumstances”, according to HMRC | Taxable if it is income received in Mauritius |
| Transfer to an approved foreign scheme (QROPS) | 25% transfer charge, with exclusions, including residence in the scheme’s country; monitoring for five tax years | — |
| Transfer to a non-approved scheme | Unauthorised payment: at least 40% | — |
| Mauritian scheme | No Mauritian scheme on the ROPS list at 15 September 2026 | — |
The ROPS list guarantees nothing
HMRC states that being on the list does not guarantee that no tax is due on a transfer. No Mauritian scheme being listed at 15 September 2026, a transfer to a Mauritian scheme cannot be presented as exempt.
Lump sums and temporary non-residence
Withdrawals from a drawdown fund and lump sums exempted by a treaty during the absence become taxable again in the United Kingdom if you return within five years (HS278).
Do not confuse capital and income
Mauritian taxation targets income (s. 5(3)): a capital sum already built up does not become taxable because it is transferred to Mauritius. But a pension lump sum may be characterised as income: have the nature of each payment determined before receiving it.
13 Estate
Can the United Kingdom still tax your estate after you leave?
Yes, for a time. Since 6 April 2025, British inheritance tax (IHT) applies to the worldwide estate of a long-term resident, and always to British assets otherwise. Domicile no longer matters. Mauritius levies no inheritance duty, and no estate tax treaty binds the two countries.
| Years of residence in the previous 20 | How long you remain a long-term resident |
|---|---|
| Fewer than 10 | You are not one |
| 10 to 13 | 3 years after departure |
| 14 | 4 years |
| 15 to 19 | One more year for each year of residence (5 to 9 years) |
| 20 | 10 years |
| Asset | Long-term resident | Not or no longer one |
|---|---|---|
| Home or account in the United Kingdom | Included | Included |
| Villa and accounts in Mauritius | Included | Excluded |
| Shares in a company whose value derives from a British home | Included | Included |
Rates and thresholds
40% above the threshold of £325,000 (36% if 10% of the estate goes to charity). The threshold rises to £500,000 when the residence passes to direct descendants, if the estate does not exceed £2 million. Thresholds frozen until 2030-31.
The transition
Not domiciled on 30 October 2024 and non-resident in 2025-26: outside the new regime. Domiciled or deemed domiciled on 30 October 2024 and non-resident in 2025-26: you leave it after three years. Ten consecutive years of non-residence reset the counter to zero.
Nothing to credit in Mauritius
As Mauritius levies no inheritance duty, no credit applies. The United Kingdom has estate tax treaties with Ireland, South Africa, the Netherlands, Sweden, Switzerland, the United States, France, Italy, India and Pakistan: not with Mauritius. A Mauritian property passes through a notary in Mauritius, under Mauritian law.
14 Gifts and spouse
Gifts, spouse and pensions: the rules that trap
IHT also applies to gifts made in the seven years before death, and the spouse is not always exempt without limit. From April 2027, unused pension funds enter the estate.
| Rule | What it provides | What you need to know |
|---|---|---|
| Lifetime gift | Exempt if the donor lives another seven years | Between three and seven years, the tax is reduced in stages: 32% between three and four years |
| Annual exemption | £3,000 per year | Can be carried forward one year |
| Gift with reservation of benefit | The gifted asset remains in the estate | Giving away the house and continuing to occupy it achieves nothing |
| Transfer to a spouse who is a long-term resident, or by a spouse who is not | Full exemption | The cap applies only in the direction of the following line |
| Donor or deceased a long-term resident, beneficiary spouse not | Exemption capped at £325,000, previous transfers to the spouse included (IHTA 1984, s. 18, 2) | Unless the spouse elects to be treated as a long-term resident; specific rules for transfers before 6 April 2025 |
| Pensions, deaths from 6 April 2027 | Unused funds and death benefits in the estate | Death-in-service lump sums and survivors’ pensions from defined benefit schemes excluded; spouse still exempt |
The mixed couple
A British long-term resident married to a Mauritian spouse who is not: what he or she gives or leaves to the spouse is exempt only up to £325,000, unless that spouse elects to be treated as a long-term resident, which brings their own entire wealth within IHT. In the other direction, from the Mauritian spouse to the British person, the exemption is full. The cap is therefore nothing automatic as soon as only one of the two is a long-term resident. To be costed with an adviser.
Giving before leaving
A gift made in the United Kingdom does not escape the seven-year rule because the donor then settles in Mauritius: as long as they are a long-term resident, their death within seven years brings it back in, Mauritian villa included.
Mauritius
No tax on gifts or on estates; a gift of Mauritian immovable property goes through a notarial deed, with its own duties.
15 Transfers and returns
Transferring your capital, filing returns, and what the authorities exchange
Neither country has exchange controls. Transferring capital already built up is not receiving income: it is the origin and nature of the funds that decide the tax, not the transfer.
Filing on arrival in Mauritius →| When | In the United Kingdom (year from 6 April to 5 April) | In Mauritius (year from 1 July to 30 June) |
|---|---|---|
| On departure | Return with SA109 (or P85); NRL1i if you let; DT-Individual for each pension | Tax number with the MRA |
| Each year thereafter | Taxable British income: rent, public pension (except the article 19 exception); NRCGT return within 60 days after a sale | Return and payment by 15 October at the latest |
| For a treaty benefit | MRA residence certificate, form DT-Individual | Tax residence certificate issued by the MRA |
| UK resident investing in Mauritius | Mauritian rent and gains in the return, Mauritian tax paid | Return of Mauritian rent |
Capital or income
The sale price of a property, savings built up before departure, an inheritance: transferred to Mauritius, these are capital. Foreign income of the year received in Mauritius is taxable. Keep the statements that date the origin of the funds: they make the difference.
Automatic exchanges
The United Kingdom is on the MRA list of reportable jurisdictions: Mauritian banks report the accounts of British residents. On request, the treaty allows the exchange of any relevant information, bank secrecy included (art. 28).
No assistance in collection
The treaty provides none; this does not erase any tax debt, British or Mauritian.
16 Case studies
Four common situations
The rules above applied to four profiles we often meet. Fictitious amounts, in pounds or rupees, calculated with the 2026-27 British rates (rest of the United Kingdom) and the Mauritian rates from the Finance Act 2026.
| Situation | What applies |
|---|---|
| An expatriate keeps his flat in Manchester | Net rent of £18,000: £1,086 of British tax in 2026-27, £1,194.60 in 2027-28 at the 22% property rate. Without NRL1i approval, the agent withholds £3,600. If he sells with a £60,000 capital gain, he files within 60 days and pays £11,743.80 (£32,270 at 18%, the rest at 24%). Mauritius taxes neither the capital gain nor the rent he leaves in the United Kingdom. |
| An entrepreneur leaves London with her company | Shares in her Ltd worth £2,000,000, subscribed for £100,000: no tax on departure. If she sells them during her absence and returns within five years, the £1,900,000 gain is taxed in the year of return, up to £455,280 at 24%, before any relief. After five years and a day, and if the company is not 75% UK property-rich, the United Kingdom no longer taxes; nor does Mauritius. |
| A retiree receives three pensions | As a British person, he sees his £20,000 local authority pension remain taxed in the United Kingdom only (art. 19, 1): £1,486 of tax if he has no other British income. His private employer pension is taxed in Mauritius for the part he has transferred there, exempt in the United Kingdom for that part only, after form DT-Individual. His State Pension is uprated and taxed in Mauritius if received there. A transfer to a Mauritian scheme would not be exempt as a matter of course. |
| A Bristol couple buys a villa in Grand Baie without leaving the United Kingdom | Rs 2,000,000 of net rent gives Rs 250,000 of Mauritian tax, credited against British tax on that rent. On resale, Mauritius levies 5% transfer tax, no tax on the capital gain; the United Kingdom taxes the gain at 18% or 24%. The villa enters their British estate. Having arrived in the United Kingdom less than four years ago after ten years’ absence, one of them could claim the FIG regime. |
17 Related guides
Going further
The main guide and the pages that detail each subject on the Mauritian side.
International taxation & MauritiusThe main guide, country by country→
Purchase costsThe real cost of a purchase, line by line→
Tax on rentThe rates applied, with worked examples→
Reselling from abroadTransfer tax and procedures→
Visas, permits and residenceAll the routes to living in Mauritius→
Living in MauritiusPreparing your departure and your first year→18 Sources & methodology
Reliable, up-to-date information
Each rule comes from the treaty, the MLI, a statute or an official publication of the British or Mauritian authorities, read on 1 October 2026. Synthesised texts were used only as a reading aid.
HMRCHM Revenue & CustomsDWPDepartment for Work and PensionsMRAMauritius Revenue AuthorityTreatyUnited Kingdom–Mauritius, 1981
- United Kingdom–Mauritius Convention signed in London on 11 February 1981 (SI 1981/1121), amended by the protocols of 23 October 1986, 27 March 2003, 10 January 2011 and 28 February 2018: consolidated text published by the British government and original published by the MRA
- OECD multilateral instrument (MLI): positions of the United Kingdom (in force on 1 October 2018) and Mauritius (in force on 1 February 2020); synthesised texts from HMRC and the MRA, read as reading aids
- HMRC: Double Taxation Digest (Mauritius sheet); RDR3 “Statutory Residence Test”; Residence and FIG Regime Manual, RFIG21030 to RFIG21130; HS278 (2026); form P85; four-year FIG regime; capital gains tax; NRCGT; non-resident landlords; SDLT surcharge; 2026-27 rates; “Inheritance Tax if you’re a long-term UK resident”; IHTM11033 and IHTM47037; pensions tax, overseas transfer charge, list of ROPS at 15 September 2026
- Finance Act 2025, schedule 10; Finance Act 2026 (c. 11), s. 4, 6 to 8, 10, 66 to 68, 72 and 74, schedule 3; Scotland Act 1998, s. 80D; Government of Wales Act 2006, s. 116E; TCGA 1992, s. 10A; IHTA 1984, s. 18
- DWP: State Pension abroad, benefits abroad; Social Security (Mauritius) Order 1981 (SI 1981/1542); British government, “Living in Mauritius”
- Mauritius: Finance Act 2026, art. 7(v); Income Tax Act, s. 5(3) and 77, Second Schedule; MRA, list of treaties in force and list of CRS jurisdictions; Bank of Mauritius: exchange controls abolished in July 1994
Texts read and verified on 1 October 2026. The British rates quoted are those for 2026-27 for England and Northern Ireland, and those enacted for 2027-28; Scotland and Wales set their own for their residents. No rule of the old non-dom regime is presented as current. This guide sets out the rules of both countries; it does not replace the advice of a tax adviser, in the United Kingdom as in Mauritius, on your situation.
19 Frequently asked questions
Your questions on taxation between the United Kingdom and Mauritius
Short answers, backed by official texts.
Frequently asked questions: United Kingdom ↔ Mauritius
Yes: signed in 1981, amended by four protocols, including the 2018 one on dividends, and by the MLI since 2021. It covers neither inheritance tax nor registration duties.
No. P85 informs HMRC and is used to obtain a refund; it does not decide your residence. It is the Statutory Residence Test, days and ties, that decides it for each year.
Not on its own. It proves your settlement in Mauritius, but the United Kingdom applies its own test; if both States treat you as resident, article 4 of the treaty decides.
No, not since 6 April 2025. It has been replaced by the four-year FIG regime for new arrivals and, for estates, by the long-term residence rule.
Not automatically. British property remains taxed, and if you return within five years, gains realised during the absence are taxed in the year of return.
In the United Kingdom, with 20% withholding by the agent or tenant unless NRL1i is approved, then in Mauritius if received there, with British tax credited.
For a non-resident, income tax follows UK rates. On purchase, the 2% non-resident surcharge exists only in England and Northern Ireland.
In Mauritius only, but the British exemption covers only the part you receive there. Have form DT-Individual endorsed by the MRA to stop British withholding.
In the United Kingdom only, unless you are a Mauritian national without being British: it then falls under Mauritius alone, like a private pension (art. 18). Outside that case, Mauritius does not tax it.
Not automatically. No Mauritian scheme is on HMRC’s ROPS list at 15 September 2026; a transfer to a non-approved scheme is taxed at no less than 40%.
On your British assets, always. On your entire wealth if you are still a long-term resident, up to ten years after leaving. Mauritius levies none.
Yes, if you are UK resident: Mauritian banks report these accounts and the MRA passes on the data under the CRS standard.