Mauritania Cross-border Tax

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

2026 research draft, source baseline only. The computations below reproduce the cited official code/provisions, not a certified complete statement of operative 2026 law. The January 2023 official code lists amendments only through the January 2022 Finance Act. Selected later Finance Acts were read, including the 2024 transfer-pricing replacement, but the complete commencement/publication chain is not closed. The signed/stamped rectifying Finance Act is visibly numbered 2026-035 on physical page 6. It changes material expense, digital-service and compliance rules; the retained comparison-column headings do not establish proposal status, and its upload date does not prove the operative date. [N02] Resolve the amendment file before using these baselines to file, pay or advise. No accountant has signed this revision.

Who this applies to

Mauritanian payers and foreign enterprises classifying services, capital income, rents and resident professional fees. Establish the actual treaty, PE and special-code position before using domestic baseline rates. This Guide owns withholding amounts; the company and individual Guides link here rather than duplicate them.

Rates, bands and thresholds

Item	Rule and conditions	Official source
Domestic permanent establishment [X01]	A fixed place through which a nonresident carries on business is a PE. Under art. 6(3)(a), construction/assembly/installation projects require more than six months for ordinary businesses or more than twelve months for petroleum subcontractors/operators. Under art. 6(3)(b), the service test includes consultancy supplied by a nonresident through employees or other personnel it engages for that purpose, with such activities continuing in Mauritania for the same or a connected project beyond those respective durations. Do not use a remote contract’s duration alone or fragment connected local projects. Read the other fixed-place, agency, insurance and preparatory/auxiliary rules; control of a company alone does not create a PE. All domestic tests remain subject to the applicable treaty.	CGI art. 6(1)–(8), especially (3)(b), physical pp. 11–12
Nonresident service withholding [X02]	Subject to treaty/special-code provisions, payments to a nonresident without a local PE for services furnished or used in Mauritania bear 15% withholding. The listed payers include real-regime businesses, government/public bodies, projects/programmes and NGOs/associations/foundations. The base includes ancillary amounts/costs paid for the provider.	CGI arts. 132–133(1)
Dividends, interest and special capital gains [X05]	Classify capital income under arts. 119–125, including exemptions in art. 122. Subject to treaties, IRCM is 10% in ordinary cases; the 20% exception concerns securities gains of a seller in a privileged-tax jurisdiction, not every dividend or interest payment.	CGI arts. 119–126
Resident professional withholding [X07]	Real-regime payers withhold 2.5% on qualifying resident liberal professionals subject to IBAPP, on invoiced tax-exclusive sums excluding disbursements. Remit by the next 15th. Credit to the professional’s IBAPP, carrying excess forward. This is not a general withholding on all resident suppliers.	CGI art. 131
Rent withholding [X08]	Public/private legal persons and real-regime individual business taxpayers occupying premises withhold 18% of rent: 10% IRF plus 8% built-property contribution. Remit by the next 15th with landlord NIF/property/month details and give the landlord the tax receipt.	CGI art. 137

The base

• Territorial business profits [C02]. Use profits of enterprises operated in Mauritania and profits allocated by a double-tax agreement. Residence means registered office or effective management in Mauritania; nonresident enterprises with a local permanent establishment are included. CGI art. 5.

• Equipment, exchange and remittance [X03]. Convert foreign-currency service payments at the rate on the payment date. Separately invoiced equipment sales within a service contract are excluded from service withholding. Remit monthly withholding by the next 15th; for an accrued unpaid service charge, pay within three months after year-end. Attach the annual supplier recap to the annual result return. CGI art. 133(3)–(7).

• PE withholding interaction [X04]. A nonresident continuing through a real local PE enters the ordinary regime. Withholding remains until filing/payment obligations are met; when they are met, withholding is a credit against the resulting tax. A fictitious local presence does not remove withholding. CGI art. 133(9)–(11).

• Foreign VAT representative and client fallback baseline [X10]. Where a person liable for VAT is established/domiciled outside Mauritania, baseline art. 221 requires accreditation of a representative domiciled in Mauritania who undertakes the formalities and payment. The representative must be a VAT taxable person identified in Mauritania. The foreign enterprise notifies DGI and provides a signed, dated mandate identifying the foreign enterprise (name/address/capital/activity), company manager’s civil status where relevant, local representative (name/address/NIF), authority to prepare returns and declare/pay monthly VAT and act locally for DGI, start date and continuing validity until DGI is notified of termination. Use a return for the foreign supplier’s operations separate from the representative’s own return. Failing that mechanism, the client pays the VAT and applicable penalties for the person without an establishment in Mauritania on a separate return. First establish liability, including the baseline art. 214 exclusion for art. 132-withheld nonresident services; do not override it with a universal reverse charge. The 2026 digital-service replacement and its commencement/implementation remain to be reconciled. CGI art. 221(1)–(4), physical p. 86, read with arts. 214, 219–220.

Deadlines and filing

• Capital withholding calendar [X06]. Capital-income tax is triggered by payment in any form and, for interest, by posting to the debit or credit of an account under art. 124(2); do not wait for a cash transfer when interest has already been entered. Withhold under art. 128 and remit by the 15th of January, April, July or October for the preceding quarter. Annual distributions/bénéficiaire statements are due before 1 April. Deemed PE distributions have the special quarter following annual-return filing rule; securities/mining disposals have their own rules. CGI arts. 124, 127–130.

Penalties and interest

• Withholding-agent liability [X09]. A person required to withhold who fails or withholds too little is personally liable for the missing withholding and related penalties. Treaty relief must be demonstrated for the actual recipient/payment rather than assumed from nationality. LPF art. L.139; CGI arts. 126, 132.

Cross-border points

The domestic PE construction/service durations are not universal treaty safe harbours. Employment domicile/work rules belong in individual income tax. VAT uses different territory/liability rules in VAT, including a baseline exclusion for nonresident services subject to art. 132 withholding. Do not collect both by assumption.

Two worked examples that recompute

1. Mixed services and separately invoiced equipment

Assume art. 132/133 applies without treaty relief, no PE and the baseline is operative. A contract separately invoices services MRU 100,000 and equipment MRU 400,000, with ancillary service costs MRU 10,000 paid for the provider. Service withholding base is 110,000 and tax 16,500. The separately invoiced equipment 400,000 is excluded from this withholding, not declared generally tax free.

name: Mixed services and separately invoiced equipment
inputs:
  services: 100000
  ancillary: 10000
  equipment: 400000
steps:
  - base: services + ancillary
  - withholding: base * 0.15
  - total_contract: base + equipment
expected:
  base: 110000
  withholding: 16500
  total_contract: 510000

2. Decide whether equipment is truly separately invoiced

Assume an otherwise identical 500,000 contract has services 100,000 and equipment 400,000. With a qualifying distinct equipment invoice, service withholding is 15,000. If the art. 133(4) separate-invoice exclusion cannot be established and all 500,000 is within the taxable service consideration, the assumed alternative is 75,000. Obtain the documents: the difference of 60,000 is not permission to relabel services as goods.

name: Decide whether equipment is truly separately invoiced
inputs:
  services: 100000
  equipment: 400000
steps:
  - distinct_invoice_tax: services * 0.15
  - alternative_tax: (services + equipment) * 0.15
  - difference: alternative_tax - distinct_invoice_tax
expected:
  distinct_invoice_tax: 15000
  alternative_tax: 75000
  difference: 60000

Ask the client first

• Recipient identity, legal form, residence, beneficial entitlement and treaty evidence?
• Exact contract: services, equipment, royalties, interest, dividend, rent or mixed supply?
• Local staff/place/agency, project durations, PE registrations and returns?
• Payment/accrual dates, currency, ancillary costs and separate invoices?
• Payer category, tax certificates and special mining/petroleum/investment regime?

Sources

Source and exact scope read	URL	Read on
cgi2023: Official version cover/amendment list and selected CGI arts. 1–14, 23–24, 40–48, 49–67, 68–98, 99–118, 119–137, 150–157, 209–215 (exemption list introductory categories only), 216–221, 227–250, 253–254, LPF L.131–L.139. Not the entire 168-page code or full sector/special regimes.	https://finances.gov.mr/sites/default/files/2023-03/CGI-Fr-2023.pdf	2026-11-01
Amendment hold: signed/stamped law 2026-035 identity on physical page 6 and art. 3.1 printed pp. 6–18 read; operative date not established	https://www.finances.gov.mr/sites/default/files/2026-08/LFR%202026%20FR.pdf	2026-11-01

Not yet confirmed: full operative 2026 amendment chain and actual treaty texts/rate-entitlement evidence; standalone blanket royalty rate asserted in the old Guide; classify the right and payment before choosing a provision; current official exchange evidence, withholding forms/boxes and portal/payment-reference steps; 2024 deemed-distribution extension to foreign contract companies and complete capital-gain/mining disposal mechanics; 2026 digital-services VAT platform/representation regime and its commencement.