February 10, 2022

The Financial Services Commission (FSC) issues policy stand on the application of the ‘Core Income Generating Activities’ requirements for Global Business License Entities.

The FSC has taken a new policy stand with regards to the core income generating activities requirement under section 71(3)(a)(i) of the Financial Services Act. This section states that “a holder of a Global Business Licence shall, at all times carry out its core income generating activities in, or from, Mauritius.” This obligation is subject to the Income Tax Act which requires entities benefitting from a preferential tax advantage to satisfy the following conditions prescribed in the Income Tax Regulations:


The company:


  1. carries out its core income generating activities in Mauritius;
  2. employs, directly or indirectly, an adequate number of suitably qualified persons to conduct its core generating activities; and
  3. incurs a minimum expenditure proportionate to its level of activities.


In light of the above and effective as from 01 January 2022, the Commission would require only holders of or applicants for a Global Business Licence that benefit or would like to benefit from a preferential tax advantage, to demonstrate that at all times their core income generating activities are or would be carried out in, or from, Mauritius.


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