Cross-border
Transfer Pricing in Mauritius: Are You Ready?
The arm's length principle now bites — here's what to document.
Arm's length principle
Related-party transactions must be priced as they would be between independent parties. The MRA can adjust and impose penalties.
Documentation
Master file, local file and — for large groups — country-by-country reports. Requirements scale with group turnover.
Common risk areas
Management fees, intra-group loans, royalties and shared services. If you can't justify the margin, expect an adjustment.
Benchmarking
Comparable company searches (typically via TP databases) support your position. A defensible benchmark is worth 10x its cost in avoided penalties.
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