The Revenue Tribunal has officially commenced operations in Mauritius as of 5 January 2026, marking a transformative shift in the way tax disputes are resolved in Mauritius. This follows the gazetting of the Revenue Tribunal Act 2025 on 7 July 2025 and its subsequent proclamation, which brings into effect a modernised, independent, and more effective framework for adjudicating tax appeals.
For many years, the Assessment Review Committee (ARC) has served as the primary body for handling objections and appeals against decisions of the Mauritius Revenue Authority (MRA) and the Registrar-General. However, the ARC’s positioning under the MRA Act and its administrative committee structure raised concerns about delays, limited formal procedures, and perceptions of insufficient independence. The introduction of the Revenue Tribunal responds to these concerns and aligns Mauritius with international best practices in tax dispute resolution.
What’s New with the Revenue Tribunal?
Fully Independent Statutory Body
Unlike the ARC, the Revenue Tribunal is established as an independent tribunal with quasi-judicial powers, separate from the MRA and political influence. Its members include a Chairperson and Vice-Chairperson (qualified legal professionals) and up to 10 experts in law, taxation, accounting, economics or business.
Clear Timelines for Appeals
The Tribunal operates within fixed deadlines designed to improve efficiency and certainty:
- Appeals must be filed within 28 days of a revenue determination.
- Witness statements should be filed within 28 days of filing of Statement of Case and Statement of Reply.
- A preliminary hearing must be scheduled within 120 days of filing.
- A final decision must be issued within 90 days after the hearing concludes, unless parties agree otherwise.
Mediation Option by Joint Request
A new feature allows taxpayers and the MRA to jointly request mediation before a full hearing. If mediators reach a settlement within 60 days, that outcome is final and binding.
Revised Pre-Payment Requirement
To file an appeal, taxpayers must still pre-pay 5% of the disputed tax. Importantly, this is now capped at MUR 5 million, providing more predictable financial exposure for high-value disputes.
Enhanced Powers and Procedures
The Tribunal can:
- Give decision orally in certain instances.
- Summon witnesses, compel the production of exhibits and take evidence under oath.
- Dismiss frivolous or vexatious appeals without a hearing.
- Award costs as appropriate.
Non-compliance or obstruction of proceedings may constitute an offence with potential fines and imprisonment.
Expanded Rights of Appeal
Under the former system, appeals to the Supreme Court were limited to questions of law. The Tribunal framework now allows for appeals on both factual and legal grounds, subject to Supreme Court procedures.
Transitional Arrangements
Existing cases before the ARC have been transitioned:
- Matters already at the hearing stage continue under the old ARC rules before the Tribunal.
- Appeals not yet heard are now governed by the Revenue Tribunal’s procedures.
The operational launch of the Revenue Tribunal ushers in a new era of transparency, independence and procedural rigour in Mauritius’s tax appeal landscape. Stakeholders are encouraged to familiarise themselves with the Tribunal’s procedures and timelines to make the most of this modernised dispute resolution framework.
