Variant Stream

Mauritius

Mauritius is situated off the southeast coast of the African continent in the southwest Indian Ocean, about 870 kilometers (540 mi) east of Madagascar.

Global Business in Mauritius
The two main types of GBCs structures in Mauritius are Global Business Company Category 1 (GBC 1) & Global Business Company Category 2 (GBC 2).  Both GBC 1 & GBC 2 need to carry out their business activities outside Mauritius & with non-residents and in currencies other than the Mauritian Rupee.
All global companies are governed by the Companies Act 2001 and regulated by the Financial Services Commission.
A GBC 1 is considered to be a tax resident in Mauritius and is subject to corporate tax at 15%.  However, a GBC 1 may claim a foreign tax credit in respect of the actual foreign tax suffered or 80% presumed tax credit, whichever is higher and this brings about for a GBC 1 to have a maximum effective tax rate of 3%.  Other tax advantages for GBC 1 in Mauritius are that there is no capital gains tax and also no withholding tax on dividends, interest and royalties paid.
The expanding network of DTAs has further reinforced Mauritius as a tax efficient jurisdiction and is also one of the prime reasons explaining the growing investment in GBC 1.     So far, Mauritius has concluded 35 treaties as detailed below:

Barbados

Croatia

Democratic Socialist Republic of Sri Lanka

Cyprus

Germany

India

France

Italy

Kuwait

Lesotho

Luxembourg

Madagascar

Malaysia

Mozambique

Namibia

Nepal

Oman

Pakistan

People's Republic of China

Rwanda

Senegal

Seychelles

Singapore

South Africa

Swaziland

Sweden

Thailand

Uganda

United Kingdom

Zimbabwe

Belgium

Botswana

United Arab Emirates

Tunisia

State of Qatar

 

Unlike a GBC 1 which has a maximum effective tax of 3%, a GBC 2 is exempt from tax in Mauritius.  Given that a GBC 2 is not tax resident in Mauritius, it cannot benefit from the DTA network.

Fact Sheet

MAURITIUS SPECIAL FEATURES

 

GBC 1

GBC 2

 

Types of corporate vehicles available

 

Public or private company
Foreign company (i.e. branch of a company established in a foreign jurisdiction)

Private company

 

Taxation & Tax Treaties

 

Access to tax treaties in Mauritius

Taxed at 15% or 3%

To be taxed at 3%, the following must be met :

  1. Minimum 2 resident Directors (nominee director allowable)
  2. Establishment in Mauritius
  3. Maintain with a local bank  an account in foreign currencies through which it conducts its trading activities

 

Tax exempted

No double tax relief

Raising of Funds

 

Permitted to involve capital raising from public

Not permitted to raise capital from public

Agent

Mandatory at all times have a registered agent

 

Mandatory at all times have a registered agent

Constitution

May or may not have a constitution

 

May or may not have a constitution

Shareholder

 

Minimum of One shareholder
Corporate shareholder allowed

 

Minimum of One shareholder
Corporate shareholder allowed

Director

 

Mandatory to have 2 resident Directors

 

One director permitted and need not be  ordinarily resident in Mauritius

Corporate director permitted

Immovable Property

 

Permitted to lease, hold, acquire or dispose of immovable property or any interest in immovable property situated in Mauritius

 

Not permitted to hold immovable property in Mauritius

Banking

 

May open and maintain with a local bank an account in Mauritian currency

May open and maintain with a bank an account in foreign currencies

 

May not hold any account in a bank in Mauritian currency

 

Holding of shares

 

Not permitted to hold shares, debentures, security or any interest in a local company

 

Permitted to hold shares, debentures or interest only in a corporation holding Category 1 or Category II Global Business Licence

Annual accounts

 

Required to file annual audited financial statements.with the Financial Services Commission & other authorities (Mauritius)

Financial summary needs to be filed with the Financial Services Commission in Mauritius