Global Business Activities
Mauritius is the only business centre in the Indian Ocean offering an attractive package of fiscal incentives and a conducive regulatory framework which has gained international recognition as a credible financial hub. With the globalization of the world economy, investors are constantly looking for an appropriate jurisdiction for commercial reasons such as access to the network of Double Tax Avoidance Agreements, total exemption from exchange control, lower operating costs, availability of highly qualified professionals, and so on.
Global Business Companies are governed by the Companies Act 2001 and the Financial Services Act 2007. Such companies may be set up by direct incorporation or by way of continuation. They can also migrate out to other jurisdictions. The regulatory body for global businesses is the Financial Services Commission (FSC).
Global Business Companies are prohibited from dealing or transacting business with local residents or from holding immovable property in Mauritius. The two main types of corporate vehicles presently available to carry on an approved global financial activity from within Mauritius, are the:
Shipping and Ship management
Aircraft financing and leasing
International Assets management
International consultancy services
International financial services
Global Insurance including Captive
Logistics and or marketing
International Licensing & franchising
Any other activity acceptable by FSC
A GBC is incorporated in accordance with the Companies Act 2001, holding a Global Business Licence issued by the Mauritius Financial Services Commission. Such type of companies is tax resident in Mauritius (unlike AC), and thus benefit from the double taxation avoidance treaty network. Although the corporate tax in Mauritius is 15%, a GBC is allowed a tax credit equivalent to the higher of the actual foreign tax suffered (underlying tax) or 80% of the Mauritius tax on its foreign source income. With an applicable tax rate of 15%, combined with a foreign tax credit of 12% (80% x 15%) the effective tax rate for the GBC will be a maximum of 3%. There are no capital gains taxes, nor exchange control.
GBC has the ability to be qualified as a tax resident in Mauritius. It is one of its features. Mauritius has extensive non-double taxation agreements signed with more than 44 counties. Therefore, Mauritius as a Financial jurisdiction can be used widely for international structuring and tax planning. There is no limit on the conduct a GBC is allowed to conduct. It can be also listed on any Stock Exchange. A minimum of one Director should be resident in Mauritius at all times. We can also provide nominee services. All shareholders can be non-residents as well.
Following the enactment of the Finance Act 2010, a GBC Company is allowed to,
The above is subject to the approval of the Authorities in Mauritius.
An Authorised Company (AC) is an appropriate vehicle for holding and managing private assets. This is the case because the shareholding can be structured via nominee shareholding which allows for greater confidentiality. The Authorised Company (AC) has the characteristics of being non-resident for tax purposes and consequently can be classified as tax-exempt entity and therefore cannot be used for tax relief under the current DTAs in force in Mauritius.
Table of Comparison between Mauritian GBC and AC
Registered Office in Mauritius
Minimum number of members
Minimum Capital Requirement
No par value shares
Access to DTA benefits
Minimum number of Directors
Minimum number of Shareholder
Annual General meeting
Filing of Financial Summary – unaudited (to FSC only)
Filing of Audited Accounts (to FSC only)
Migration into and out of Mauritius
About 15/20 days
Max 5 days
Processing fees (ROC & FSC)
Annual licence fees
US $ 1,750
US $ 235
Annual Registration fees
Double Taxation Treaties(DTA)
Double Taxation Treaties (DTA)
Mauritius has several double taxation treaties which are replicated on the OECD Model Treaty. Under the tax arrangements, tax sparing is available. Consequently, due to the current tax incentive provisions, any dividends sourced from Mauritius are therefore exempt from tax and as a result the foreign investor is entitled to a credit which is the notional amount of Mauritius tax against the tax due is therefore lessening his domestic tax liability.
Tax Treaties in force or under negotiation
Mauritius is a party to over 44 treaties which has been ratified. There are many other treaties that are currently being negotiated. One example, of a treaty that has been used widely, is the treaty Mauritius had with India. Mauritius, via this treaty, became the dominant channel for FDI in India. There is a series of updates, regarding this treaty with India, during the past years
Tax Treaty Benefits
Benefits from tax treaties are only available for resident entities or persons. Therefore, the liability of tax for a resident entity in Mauritius will be inherent under Mauritian Law by virtue of its domicile or residence. Mauritius has a multitude of structures available including the GBC and AC, the Société, and the Trust.
Consequently, a foreign entity or company, inclusive of the Global Business Company can take advantage or benefit from the tax treaty network. A Mauritian branch of a foreign entity can access the benefits derived from the tax treaties by meeting the conditions for residence. Furthermore, these related entities need to apply for a Tax Residence Certificate if they want to use the tax benefits under the treaties.
It is interesting to note that a resident in Mauritius, deriving income from a foreign country, whereby there is no applicable tax treaty in place between Mauritius and that foreign country, will still receive a credit (relative to the foreign income) which can be used to offset any Mauritian income tax.
However, the credit is restricted on a source-by-source basis to the lesser of the 2 followings:
Regarding foreign source dividends, there is no credit relief if granted for foreign corporate income tax borne on the profits out of which the dividends are paid (in result to the underlying tax)
For further information on DTA treaties please contact us and we shall be pleased to assist you.
Customer Due Diligence and enhanced due diligence (Know-Your-Client)
In line with our internal control and procedures and in conjunction with FSC code on prevention of money laundering and terrorist financing, we shall conduct a customer due diligence on our clients (both individuals and corporates). A KYC review will be done sporadically to satisfy all the requirements as per the prevailing legislation, codes and guidelines. The KYC documents required on individual shall be: -