Mauritius’ Supreme Court clarifies the Foreign Tax Credit (“FTC”) regime in UPL Corporation Ltd v Revenue Tribunal & Anor (2026 SCJ 161).
The Court confirmed that the actual foreign tax and the 80% presumed FTC can be combined under the pooling method, while maintaining the cap at Mauritian tax payable.
A concise, taxpayer-friendly ruling that brings greater flexibility for Category 1 Global Business Companies.
