Tax Disputes: The Revenue Tribunal Takes the Stage

The Revenue Tribunal has been operational since January 5, 2026. Established under the Revenue Tribunal Act, it was created as an independent body tasked with handling appeals related to tax matters, replacing the Assessment Review Committee (ARC).

This new tribunal aims to be structured, transparent, and accessible in dealing with tax appeals. It seeks to simplify the appeals process, enhance transparency and reliability of the system, while improving access to justice for taxpayers.

The establishment of this body was among the goals of the government, as announced in its government program of January 2025. Its creation necessitated the introduction of a new law, specifically the Revenue Tribunal Act.

This reform marks a significant step in the institutional landscape of tax dispute resolution in Mauritius. It is part of an ongoing effort to streamline and modernize the process, ensuring a fairer, more accessible, and more efficient system.

The objective of creating an independent and autonomous tax tribunal has frequently appeared on the legislative agenda of governments since 2013.

As early as 2011, a report from the International Monetary Fund (IMF) on Mauritius pointed out the weaknesses in the existing system.

"The formal mechanism for the appeals process has significant limitations, highlighting the need for a substantial overhaul to ensure fairness, transparency, and efficiency. On the other hand, although the provisions governing the Assessment Review Committee (ARC) have been integrated into the Mauritius Revenue Act (MRA Act), it is important to note that the ARC remains independent of the MRA. The inclusion of these provisions in the MRA Act could mislead potential investors regarding the actual autonomy of the ARC."

Opinion of the Attorney General

During the presentation of the Revenue Tribunal Act to the National Assembly, Attorney General Gavin Glover emphasized the fundamental issues of this reform. He stated, "However autonomous and unbiased the Assessment Review Committee may be, it remains conceptually part of the [Mauritius Revenue] authority whose decision it reviews."

Given the quasi-judicial nature of its functions, it was deemed more appropriate for these to be performed by a full-fledged tribunal.

The Revenue Tribunal, he specified, will be an autonomous body, created by its own law, with its own secretary and staff, and placed under the administrative authority of its president.

"This separation is not superficial. It reinforces public confidence, particularly that of foreign investors, who are accustomed to tax disputes being handled outside the legal framework of the tax administration."

What Changes

The Revenue Tribunal Act introduces several fundamental changes aimed at enhancing the integrity and efficiency of the appeals process.

The tribunal has expanded powers, including the ability to summon any individual by subpoena, require the production of documents, and collect sworn testimonies, thereby strengthening the credibility of the process.
Failing to appear before the tribunal or refusing to testify is now considered an offense.
The tribunal is required to set a preliminary hearing within 120 days of the filing of the appeal and must render its decision within a maximum of 90 days.
After the conclusion of hearings, it can rule orally on any procedural or legal matters and dismiss evidently unfounded appeals outright.
Anyone feeling aggrieved by a decision of the Revenue Tribunal can appeal to the Supreme Court.
Under the ARC, taxpayers had to pay 5% of the contested tax amount, with no legal cap. Now, the Revenue Tribunal Act sets a cap of five million rupees.

Rules

In most cases, filing an appeal is done through a form available on the tribunal's website (https://rt.govmu.org) or directly at its counter. The complainant is then summoned for a preliminary hearing.
A request for mediation can be made to resolve the dispute without a formal hearing. This process is both informal and quick.
Individuals not engaged in business activities, as well as businesses with a declared gross income of less than Rs 10 million for the relevant fiscal year, are exempt from certain documentary requirements.
Procedures will be conducted in a simplified manner, avoiding non-essential formalities.

Tribunal Priorities

Eliminate unjustified delays in the administration of justice, particularly by limiting postponements as much as possible.
Ensure effective management of appeals and promote predictability of decisions, in the interest of justice.
Ensure the resolution of disputes within reasonable time frames, in accordance with Article 10(8) of the Constitution, which guarantees "a fair trial within a reasonable time."

Who Can Bring a Case to the Tribunal?

Any person who feels aggrieved by a decision of the Director General of the Mauritius Revenue Authority (MRA) or the Registrar General can bring a case before the Revenue Tribunal.

Headquarters

The tribunal is located on the 2nd floor of the Pope Hennessy Building, Pope Hennessy Street, Port-Louis.
It operates Monday to Friday, with hearings from 10:00 AM to 12:00 PM and from 1:00 PM to 3:30 PM.

Who Serves on the Tribunal?

The tribunal currently consists of an interim president, former magistrate Goolshan Sharma Jorai, and two vice-presidents, Mr. Dinesh Appa Jala and Mr. Vidyaprakash Ganesh Bakee, appointed by the Public Service Commission and possessing legal training.
The assessors are Anamalay Pyanee, tax specialist; Anita Devi Naga, with 45 years of service in the Registrar General’s Department; Dhanee Seetloo, experienced in taxation and revenue; Fazullah Abdoolatiff, with technical expertise; Goolam Hussen Sookeechand, Chartered Certified Accountant; and Deviantee Sobarun, specializing in Land and Revenue Law.
Each division of the tribunal examines cases within a panel of three, including the president or a vice-president and two assessors with expertise in accounting, economics, taxation, law, or business administration.