Revenue Tribunal Act 2025 — Purpose & Coverage
The Revenue Tribunal is an independent forum that hears appeals from determinations issued by the Director-General (MRA) and the Registrar-General across specified tax enactments. It excludes compounding decisions and police referrals, provides powers to compel attendance/production and to award costs, offers an optional 60-day mediation route, and runs on statutory timelines with a capped deposit rule.
Acts & Sections Covered by Revenue Tribunal
Income Tax Act
Section 134
Value Added Tax Act
Sections 20D(6), 40(1), 66(7)
Customs Act
Multiple sections (9A, 15, 19, 20, 23, 24, etc.)
Land (Duties & Taxes) Act
Sections 15A, 23, 24, 26A, 28(4), 39(2)
Registration Duty Act
Section 17
Excise Act
Sections 5(4), 22(7), 52(7)
Gambling Regulatory Authority Act
Sections 121(4), 121(5), 122(2)
Environment Act 2024
Part IX
Other tax-related enactments
As specified in the Act
Key Changes from Assessment Review Committee (ARC)
- Burden of proof: In anti-avoidance matters the DG/RG carries the burden and is heard first Act s.9(1), s.9(4)
- Deposit cap: 5% of determined amount, capped at MUR 5,000,000 Act s.6(6)(a)
- Timelines: preliminary ≤120 days; decision ≤90 days after hearing (exceptional cases with consent) Act s.7(7)(a), s.7(7)(c)
- Powers: costs and dismissal of frivolous/vexatious appeals without oral hearing Act s.10(5), s.10(4)
- Mediation: 60-day mediation; agreement final & not a precedent Act s.8(1)–(2), s.8(4)–(5), s.8(7)
Differences between ARC and Revenue Tribunal at a glance
The table below sets out a concise, side-by-side comparison of the former Assessment Review Committee (ARC) regime and the new Revenue Tribunal. Use it as a quick checklist for practical differences—burden of proof, deposit rule, timelines, and powers. The right-hand column includes pinpoint section references from the Act for easy verification.
| Feature | Assessment Review Committee (ARC) | Revenue Tribunal |
|---|---|---|
| Burden of proof | On appellant (taxpayer) | Generally on appellant; in anti-avoidance cases (LDTA s39, ITA s90, VAT s36A) the DG/RG is heard first and carries the burden Act s.9(1), s.9(4) |
| Deposit for appeal | 5% of amount claimed | 5% of determined amount, capped at MUR 5,000,000; Chair may still direct a hearing despite non-payment where satisfied of reasonable cause Act s.6(6)(a)–(b) |
| Preliminary hearing | ≈1 month (practice) | Fixed within ≤120 days after the appeal is lodged Act s.7(7)(a) |
| Final decision | Target timelines (discretionary) | Issued ≤90 days after the hearing closes (save in exceptional cases with parties’ consent) Act s.7(7)(c) |
| Costs | Limited | May award costs (e.g., to the successful party) Act s.10(5) |
| Frivolous / vexatious appeals | No clear power | May dismiss without an oral hearing Act s.10(4) |
| Summons / oath | Limited sanctions | Orders attendance/production; evidence may be taken on oath; non-appearance/refusal is an offence Act s.7(5)(a)–(b), s.12(a)–(c) |
| Jurisdiction note | — | Hears penalties and surcharges (not interest) Act s.6(7) |
| Mediation | Occasional practice via chair/vice-chair with parties’ consent | Joint written request; 60-day limit; agreement is final & binding and not a precedent Act s.8(1)–(2), s.8(4)–(5), s.8(7) |
| Appeal to Supreme Court | Historically focused on points of law (practice) | Notice within 21 days; recognisance with sureties; within 14 days lodge at SC, pay fees, serve parties & file return of service; respondent has 28 days to resist Act s.11(1), s.11(3)–(4), s.11(6)(b)–(c) |
| Late appeal admission | — | Chair may admit late appeal only where satisfied there was illness or other reasonable cause Act s.6(5) |
Appeal & Decision Time Limits — Revenue Tribunal
Appeals run on strict legal deadlines. After you lodge an appeal, the Tribunal must fix a preliminary hearing, and once the hearing closes it must issue a written decision within a set time. If you still disagree, there is a short window to pursue a Supreme Court appeal. The timeline below shows the maximum limits set by law (with the exact section numbers). Missing a deadline can end your case; late appeals may be admitted only where the Chair is satisfied there was illness or other reasonable cause.
1
Lodge AppealWithin 28 days
Act s.6(1)
2
Preliminary HearingWithin 120 days
Act s.7(7)(a)
3
Final DecisionWithin 90 days of hearing (exceptional cases with consent)
Act s.7(7)(c)
4
Supreme Court AppealNotice within 21 days
Act s.11(1)
Process Flow — Tribunal Appeal & ATDR (with legal anchors)
This flowchart sets out the mandatory steps and decision points for
tax assessments, objections & appeals, and
tribunal proceedings—including timelines, deposit requirements, mediation,
and the ATDR route—so taxpayers and advisers can navigate the process confidently.
Step-by-step guide: Lodge appeal → Preliminary hearing → Mediation / ATDR / Formal hearing
→ Tribunal decision → Supreme Court appeal. Each box includes a concise legal reference.
ATDR (Alternative Tax Dispute Resolution) Panel
What is ATDR?
The Alternative Tax Dispute Resolution (ATDR) Panel is a voluntary, settlement-focused pathway for high-value tax disputes. It runs alongside the objection/appeal process and aims to resolve matters by agreement rather than a full Tribunal hearing. You must already have an objection or appeal on foot; applying to ATDR does not pause statutory deadlines. If both sides reach agreement, it is final and binding and not a precedent; otherwise the case returns to the normal route. (Reference: ATDR Guidelines §1–§5; MRA Act s.21C)
What is ATDR?
The Alternative Tax Dispute Resolution (ATDR) Panel is a voluntary, settlement-focused pathway for high-value tax disputes. It runs alongside the objection/appeal process and aims to resolve matters by agreement rather than a full Tribunal hearing. You must already have an objection or appeal on foot; applying to ATDR does not pause statutory deadlines. If both sides reach agreement, it is final and binding and not a precedent; otherwise the case returns to the normal route. (Reference: ATDR Guidelines §1–§5; MRA Act s.21C)
- Eligibility: Dispute > Rs5M; objection/appeal already filed; no relevant convictions/inquiries; same grounds ATDR Guidelines §3
- Panel: Director (Chair), Senior MRA Officer (designated by DG), Law Practitioner (appointed by Minister) ATDR Guidelines §1
- Timeline: Decision within 6 months; if not agreeable, notify within 1 month → objection/appeal determined within 4 months ATDR Guidelines §5(b), §5(f)
- Outcome: Agreement final & binding, not a precedent; if under appeal, file with Tribunal/SC/PC ATDR Guidelines §5(c)–(e). Note: leaflet still uses “ARC”; read as “Revenue Tribunal”.
- Apply: This email address is being protected from spambots. You need JavaScript enabled to view it. ATDR Guidelines §4
When is ATDR a good fit?
- You want a pragmatic, quicker settlement with certainty of outcome.
- The dispute is mainly about values or interpretation, not complex factual disputes.
- You prefer to avoid the cost and formality of a full hearing.
When it may not suit
- You want a judicial ruling/precedent from the courts.
- There are relevant convictions/ongoing inquiries, or the grounds differ from your objection/appeal.
What to prepare
- Concise statement of facts and issues (same grounds as your objection/appeal).
- Computation(s) showing amounts in dispute and any proposed settlement basis.
- Key supporting documents you want the Panel to consider.
How to read this flowchart
Use this as your orientation: box styles distinguish actions from decisions, highlight any payment checkpoints, and mark the start/end and closure of a case—so you can follow the arrows confidently while checking the cited sections.
PROCESS / MANDATORY STEP
White box with brown border
White box with brown border
DECISION POINT
Cream rounded box
Cream rounded box
PAYMENT / DEPOSIT
Cream with dashed border
Cream with dashed border
START / END
Dark brown background
Dark brown background
FINAL RESOLUTION
Green = matter closed
Green = matter closed
INVESTIGATION & ASSESSMENT
DG (MRA) or Registrar-General investigates, assesses, determines penalties/surcharges
TAX BREACH DETECTED
Non-compliance under any covered enactment (Income Tax, VAT, Customs, Land Tax, etc.)
FORMAL DETERMINATION ISSUED (through OADR)
Assessment breakdown:
• Penalties/surcharges
• Payment deadlines
• Appeal rights notice
• Penalties/surcharges
• Payment deadlines
• Appeal rights notice
OADR outcome
At this point you must choose: do nothing / pay OR file an appeal
NOT AGGRIEVED or NO APPEAL LODGED
PAYMENT REQUIRED
Payment of all amounts due within 28 days
↓
Taxpayer must pay:
- Full assessed tax amount
- All penalties imposed
- Surcharges calculated
- Accrued interest (per relevant Acts)
↓
CASE CLOSED
No further recourse available
AGGRIEVED & APPEAL FILED [s.6(1)–s.6(2)]
LODGE APPEAL
File with Secretary to Tribunal
↓
Required documents:
- Detailed grounds of appeal
- Supporting documentation
- Serve copy to all parties
- Pay filing fees
↓
TIME CHECK
Appeal WITHIN 28 Days of determination
Chairperson may extend only for illness or other reasonable cause.
Act s.6(1), s.6(2), s.6(5)
Chairperson may extend only for illness or other reasonable cause.
Continue below only if you chose “Aggrieved & Appeal Filed”.
IS IT AN EXCLUDED DETERMINATION?
Compounding decision or referral to police Act s.6(4)
Compounding decision or referral to police Act s.6(4)
YES
NO APPEAL ALLOWED
Act s.6(4)
Act s.6(4)
NO
DEPOSIT REQUIREMENT (if applicable)
5% of determined amount or MUR 5M (whichever is lower). Chairperson may still direct a hearing despite non-payment where satisfied of reasonable cause. Act s.6(6)(a)–(b)
5% of determined amount or MUR 5M (whichever is lower). Chairperson may still direct a hearing despite non-payment where satisfied of reasonable cause. Act s.6(6)(a)–(b)
PATHWAY CHOICE
Choose dispute resolution method
Choose dispute resolution method
OPTION A: REVENUE TRIBUNAL
Formal judicial process
Formal judicial process
LODGE APPEAL
Lodge with Secretary; Serve grounds; Chairperson refers to a division Act s.6(2)–(3)
Lodge with Secretary; Serve grounds; Chairperson refers to a division Act s.6(2)–(3)
OPTION B: ATDR PANEL
Alternative settlement mechanism
Alternative settlement mechanism
ATDR ELIGIBILITY
Dispute > Rs 5M; Objection/appeal already lodged; No relevant convictions/inquiries; Same grounds ATDR Guidelines §3 (MRA Act s.21C)
Dispute > Rs 5M; Objection/appeal already lodged; No relevant convictions/inquiries; Same grounds ATDR Guidelines §3 (MRA Act s.21C)
MEDIATION / SETTLEMENT OPTION
Choose settlement approach
Choose settlement approach
REVENUE TRIBUNAL MEDIATION
• Parties jointly request in writing
• Chairperson appoints mediators / refers to panel
• 60-day time limit
• Agreement final, binding & not a precedent Act s.8(1)–(2), s.8(7), s.8(4)–(5)
• Parties jointly request in writing
• Chairperson appoints mediators / refers to panel
• 60-day time limit
• Agreement final, binding & not a precedent Act s.8(1)–(2), s.8(7), s.8(4)–(5)
ATDR SETTLEMENT
• Runs while objection/appeal is on foot
• Decision within 6 months; fallback determination within 4 months if no agreement ATDR Guidelines §5
• Runs while objection/appeal is on foot
• Decision within 6 months; fallback determination within 4 months if no agreement ATDR Guidelines §5
FORMAL HEARING
• Evidence may be taken on oath Act s.7(5)
• Orders for attendance/production
• Sanctions for non-appearance/refusal Act s.12
• Evidence may be taken on oath Act s.7(5)
• Orders for attendance/production
• Sanctions for non-appearance/refusal Act s.12
• Preliminary hearing fixed ≤120 days after the appeal is lodged Act s.7(7)(a)
• Final decision ≤90 days after the hearing closes (save in exceptional cases with parties’ consent) Act s.7(7)(c)
• Final decision ≤90 days after the hearing closes (save in exceptional cases with parties’ consent) Act s.7(7)(c)
BURDEN OF PROOF
Generally on appellant; in anti-avoidance cases (LDTA s39, ITA s90, VAT s36A) DG/RG are heard first and carry the burden.
Generally on appellant; in anti-avoidance cases (LDTA s39, ITA s90, VAT s36A) DG/RG are heard first and carry the burden.
TRIBUNAL DECISION
• Confirm, Amend, or Quash determination
• Costs may be awarded
• Frivolous/vexatious appeals may be dismissed without oral hearing Act s.10(1), s.10(5), s.10(4)
• Confirm, Amend, or Quash determination
• Costs may be awarded
• Frivolous/vexatious appeals may be dismissed without oral hearing Act s.10(1), s.10(5), s.10(4)
FINAL DECISION
Aggrieved by Tribunal decision?
Aggrieved by Tribunal decision?
NO
FINAL & BINDING
Decision implemented Act s.10(7)
Decision implemented Act s.10(7)
YES
SUPREME COURT APPEAL
• Written notice to Secretary ≤21 days
• Recognisance with one or more sureties + sum to cover costs
• Within 14 days after notice: lodge at SC, pay fees, serve parties, file return of service
• Respondent to file notice to resist within 28 days (else deemed not to resist) Act s.11(1), s.11(3)–(4), s.11(6)(b)–(c)
• Written notice to Secretary ≤21 days
• Recognisance with one or more sureties + sum to cover costs
• Within 14 days after notice: lodge at SC, pay fees, serve parties, file return of service
• Respondent to file notice to resist within 28 days (else deemed not to resist) Act s.11(1), s.11(3)–(4), s.11(6)(b)–(c)
Effect of appeal: Tribunal decision remains enforceable pending SC appeal (subject to LDTA refund exception).
Act s.11(7)–(8)
Important notice
This material is provided for educational and informational purposes only and is not legal advice.
It does not create a lawyer-client relationship, and you should not act or refrain from acting on the basis of this
summary without obtaining advice from qualified counsel on your specific facts. While care has been taken to align
this guide with the Revenue Tribunal Act 2025 and the ATDR Guidelines. Laws and guidance may change; timelines and requirements may vary by circumstances.
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