You have capital to grow, international mobility, and legitimate expectations: where should you invest to optimize taxation, returns, legal security, and quality of life at the same time? Mauritius, Dubai, Portugal, or Bali? These four destinations currently attract the bulk of private investment flows from HNWI (High Net Worth Individuals) and HENRY (High Earner, Not Rich Yet) clients.
This comparative guide provides the key insights to help you decide and explains why Mauritius deserves to be at the top of your shortlist.
Why these four destinations stand out in 2025
These markets share several key characteristics that appeal to international wealth investors:
- Attractive tax regimes, or even zero taxation for non-residents
- Residency pathways linked to real estate investment
- Markets driven by strong rental demand (expatriates, tourists, digital nomads)
- Generally stable legal environments, oriented toward foreign investment
However, their profiles are fundamentally different. A serious comparison must go beyond clichés.
Taxation: where do you really make more money?
Mauritius
Mauritius offers one of the most competitive tax regimes in the world for residents. Income tax is capped at 15% (with a reduced rate of 10% below a certain threshold). What truly sets Mauritius apart is the complete absence of capital gains tax, inheritance tax, wealth tax, and dividend tax for residents. The country also benefits from a network of more than 45 double taxation treaties — including one with France — preventing double taxation.
Key point: A French investor who becomes a tax resident in Mauritius can legally exit the French tax system and benefit from an overall effective tax rate often below 10% on global income.
Dubai
Dubai (United Arab Emirates) is known for its 0% personal income tax. There is also no capital gains tax on real estate or inheritance tax. However, Dubai applies a 5% VAT introduced in 2018 and implemented a corporate tax of 9% in 2023 on profits exceeding 375,000 AED (~€100,000). The absence of a tax treaty with France also exposes French residents to potential disputes with the French tax authorities if relocation is not properly structured.
Portugal
The NHR (Non-Habitual Resident) regime, renamed IFICI in 2024, previously allowed significant tax exemptions on foreign income. The framework has since evolved and is now more restricted to specific profiles. Capital gains tax remains at 28%, and the overall tax burden is significantly higher than in Mauritius or Dubai.
Bali
Indonesia does not offer a tax regime specifically designed for foreign investors. In Bali, direct property ownership by non-citizens is prohibited (ownership is structured through local entities or long-term leasehold arrangements), which complicates and weakens long-term wealth planning and asset security.
Entry ticket and access to residency
Access to the real estate market and investment-linked residency varies significantly depending on the destination:
Mauritius — PDS / IRS / RES / Smart City schemes or G+2
Foreigners can purchase property in Mauritius under official schemes (PDS, IRS, RES, Smart City), as well as G+2 developments (apartments outside structured real estate schemes, in buildings of two storeys or more open to foreign buyers). The minimum investment threshold (excluding G+2) to obtain residency rights is set at USD 375,000. The process is transparent, regulated by the Economic Development Board (EDB), and permanent residency can be granted upon completion of the purchase deed.
Dubai — Investor visa
Dubai offers a 2-year residency visa for real estate investment starting from AED 750,000 (~USD 205,000), and a 10-year Golden Visa for investments of at least AED 2,000,000 (~USD 545,000). The market is highly liquid, and prices have risen significantly over the past three years (+40% to +60% in certain premium areas), which effectively increases the entry ticket for high-quality assets.
Portugal — Golden Visa
Portugal has significantly restricted its Golden Visa program since 2023: residential real estate investments in major cities (Lisbon, Porto, Algarve) are no longer eligible. Entry tickets now start at €500,000 for qualifying investment funds. The residency comes with a minimum stay requirement (7 days per year).
Bali — Uncertain legal framework
Bali does not offer a structured real estate investment program for foreign investors. Available property rights (Hak Pakai) are time-limited and do not allow for fully secure, long-term asset ownership in the Western sense.
Comparative summary table
| Criteria | Mauritius | Dubai | Portugal | Bali |
| Income Tax | 15 % max (residents) | 0 % | 10–48 % | 0–30 % |
| Capital gains tax | 0 % | 0 % | 28 % | Variable |
| Entry threshold (residency) | $ 375,000 (PDS, IRS, RES, Smart City) | $205,000 (residency) | €500,000 (Golden Visa) | No clear scheme |
| Gross rental yield | 4–7 % | 5–9 % | 4–6 % | 6–12 % (seasonal) |
| Political/legal stability | ★★★★★ | ★★★★☆ | ★★★★★ | ★★★☆☆ |
| Quality of life (expat score) | Very high | High | High | Medium-high |
| Foreign property ownership | Yes | Yes (designated zones) | Yes | Limited (leasehold only — Hak Pakai) |
Sources: Economic Development Board Mauritius, Dubai Land Department, Banco de Portugal, market data 2024–2025.
Rental yields: the real figures
Gross yield is often highlighted in sales arguments. However, it is essential to factor in holding costs, local taxation on rental income, and market liquidity in order to assess the true net return.
Mauritius
Villas and apartments in managed resort residences (IRS/PDS) show gross rental yields of 4% to 7%, with contractual rental guarantees offered by hotel operators. Property taxes are minimal. Rental demand from expatriates and premium clients ensures stable occupancy throughout the year.
Dubai
Dubai offers some of the highest gross rental yields globally (5% to 9% depending on the area), driven by exceptionally strong rental demand. However, price volatility, high service charges, and increasing supply of new developments can compress net yields over time. The market is cyclical and has experienced significant corrections (2009, 2015–2016).
Portugal
Portugal offers solid rental yields (4% to 6%). However, taxation on rental income (28% flat tax or progressive brackets) and increasing regulatory pressure on short-term rentals (Airbnb-style lets) in major cities reduce its long-term attractiveness as a pure investment market.
Bali
Reported yields in Bali (sometimes 10%–15% for short-term rentals) appear attractive but remain fragile: they depend on highly seasonal tourism, complex local management, and an uncertain legal framework for foreign investors.
Quality of life: the decisive factor for premium profiles
An HNWI investor rarely separates real estate investment from lifestyle considerations. Quality of life, safety, natural environment, and social stability often weigh as much as financial performance indicators.
Mauritius
Mauritius is consistently ranked as one of the leading retirement and expatriation destinations in Africa and the Indian Ocean region. It combines an exceptional natural environment (lagons, nature reserves, unspoiled coastline), high-quality international infrastructure (bilingual schools, top-tier private clinics, direct flights to major global capitals), strong political stability among the best in Africa, and a multicultural, welcoming society with both French and English influences.
Dubai
Dubai offers a highly modern urban infrastructure, an unmatched nightlife and commercial environment, and exceptional public safety. In contrast, its natural environment is almost non-existent, summer temperatures are extreme (up to 48°C), and the societal model remains subject to certain cultural constraints for Western families.
Portugal
Portugal appeals with its Mediterranean lifestyle, moderate cost of living, gastronomy, and rich cultural heritage. However, it is currently facing a severe housing crisis in major cities and increasing pressure from mass tourism.
Bali
Bali is attractive for its unique spiritual and natural environment. However, medical infrastructure remains limited for families, international connectivity is weaker, and the legal framework does not provide sufficient reassurance for long-term investors.
Legal stability and security: the often underestimated criterion
For wealth intended to be passed on, the strength of the legal framework is essential. Mauritius benefits from a legal system derived from both English common law and French civil law, an independent judiciary, and a stable sovereign credit rating. The country is regularly ranked among the top 10 in Africa in the World Bank governance indicators.
Dubai offers strong contractual security within regulated zones (notably the DIFC), but the absence of representative democracy and reliance on the sovereign decisions of the emirate create non-negligible systemic risks in the long term.
Portugal, as a member of the European Union, offers the strongest guarantees in terms of property rights and legal recourse — but at the cost of a significantly higher tax burden.
Why Mauritius stands out for the discerning investor
At the end of this comparative analysis, Mauritius presents a unique profile: it is the only destination that simultaneously combines:
- One of the most competitive tax regimes in the world (0% on capital gains, 0% on inheritance, maximum 15% on income)
- A strong and transparent legal framework, internationally recognized
- Full freehold property ownership for foreigners under approved schemes
- Exceptional quality of life in a preserved natural environment
- Permanent residency granted from a USD 375,000 investment
- Political and social stability among the strongest in Africa and the Indian Ocean region
- A strategic geographical position between Africa, Asia, and Europe
It is not a destination for short-term speculative gains — it is the destination for long-term wealth preservation and sustainable wealth building.
Côté Sud: your premium real estate partner in Mauritius
Côté Sud is a real estate agency specializing in exceptional properties in Mauritius. We support an international clientele — business owners, family offices, retirees, and institutional investors — throughout every stage of their investment journey:
- Selection of premium properties (beachfront villas, serviced apartments, private estates)
- Legal and tax structuring advice, in coordination with our partners including the EDB, notaries, and local attorneys
- Assistance with residency procedures (Occupation Permit, permanent residency)
- Rental management and post-acquisition wealth monitoring
- On-the-ground presence and in-depth knowledge of the Mauritian property market
Whether you are comparing opportunities in Mauritius with other international markets, or already convinced by the island, our team provides a 360° perspective to help you make the most informed wealth decision.
FAQ — Frequently asked questions from investors
Can foreigners freely purchase property in Mauritius?
Yes, under official schemes (PDS, IRS, RES, Smart City, G+2). These frameworks allow full freehold ownership and provide access to permanent residency from a minimum investment of USD 375,000.
Mauritius vs Dubai: what is the main tax difference for a French resident?
In Dubai, the absence of a double taxation treaty with France exposes investors to potential double taxation risks if relocation is not properly structured. Mauritius has had a bilateral tax treaty with France since 1980, providing a secure legal framework for tax residency transfers.
What rental yield can be expected in Mauritius?
Gross rental yields in managed residences typically range from 4% to 7%, depending on location and property type. Some operators offer contractual rental guarantees over 3 to 5 years.
Do you need to physically reside in Mauritius to obtain permanent residency?
No. Investing in an eligible property is sufficient to trigger residency rights. There is no strict minimum stay requirement, although physical presence is generally required to establish tax residency (183 days/year).
Does Côté Sud work with non-French-speaking clients?
Yes. Our team is bilingual in French and English and works with an international clientele. Mauritius is a bilingual country, and all legal documents can be drafted in English.
Conclusion
Investing in Mauritius or Dubai ultimately means choosing between two distinct wealth philosophies: the fast, speculative growth of a hyper-dynamic urban market, or the long-term construction of wealth in a stable, tax-efficient environment offering an irreplaceable quality of life.
For investors seeking to protect, transfer, and grow their assets within a secure legal framework, while enjoying an exceptional lifestyle, Mauritius stands today as the most comprehensive solution.
Côté Sud is here to support you, step by step, in bringing this project to life.
