The Mauritius government has published substance requirements for the partial exemption regime introduced at the beginning of 2019 to replace the deemed foreign tax credit regime. The regulations determine income attributable to a controlled foreign company and entitlement to the 3 per cent preferential tax rate, with effect from 1 July 2019. The preferential rate only applies if the company carries on its core income generating activities (CIGA) in Mauritius, employs an adequate number of suitably qualified persons to conduct its CIGA, and incurs a minimum expenditure proportionate to its level of activities.