Overview

 

Mauritius Global Business companies (GBC) are incorporated under the Mauritius Companies Act 2001, as amended and licensed by the Mauritius Financial Services Commission (“FSC”). They are resident in Mauritius for taxation purposes and have access to the extensive double taxation avoidance treaty network, provided they hold a Tax Residence Certificate issued by the Mauritius Revenue Authority.

 

Substance requirement

 

In order to issue a GBC Licence, the Mauritius FSC considers whether the company has substance in Mauritius through its management and control. The following substance requirements are considered:

1. The Company shall have at least 2 directors, resident in Mauritius;

2. The Company shall maintain at all times its principal bank account in Mauritius;

3. The Company shall keep and maintain, at all times, its accounting records at its registered office in Mauritius;  

4. The Company shall prepare its statutory financial statements and causes such financial statements to be audited in Mauritius;

5. The Company shall provide for all meetings of directors to include at least 2 directors from Mauritius; and

 

The Company must meet, at all times, the following additional pre-defined substance requirements:

 

1. carry out its core income generating activities in, or from, Mauritius, as required under the Mauritius Income Tax Act, as amended and this includes:

   • carrying out its core income generating activities in Mauritius;

   • employing, directly or indirectly, an adequate number of suitably qualified persons to conduct its core income generating activities; and

   • incurring a minimum expenditure proportionate to its level of activities.

2. be managed and controlled from Mauritius; and

3. be administered by the Management Company, Premier Financial Services Limited.

 

Taxation

 

1. There is no capital gains tax or withholding tax in Mauritius

2. Mauritius taxation is 15% flat rate. Nevertheless, an 80% Partial Exemption Regime is applicable in the following circumstances 

• Foreign dividend derived by a company;

• Interest derived by a company (excluding bank);

• Income derived by CIS closed ended fund, CIS manager, CIS administrator,

• Investment advisor or asset manager;

• Income derived by companies engaged in the leasing of ships or aircrafts;

• Profits attributable to a permanent establishment of a resident company in a foreign country;

• leasing and provision of international fibre capacity;

• reinsurance and reinsurance brokering activities; and

• sale, financing arrangements and asset management of aircraft and its spare part including aviation related advisory services.

 

Others – Global Trading

 

Effective from 1 Jan 2019, the definition of “export of goods” includes international buying & selling of goods by an entity in its own name, whereby the shipment of such goods is made directly by the shipper, in the original exporting country, without the goods being physically landed in Mauritius. As a result, companies engaged in global trading qualify for the 3% income tax rate on export of goods. GBCs may avail of this corporate tax rate.

 

Key features

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